Privacy Policy
February 3, 2023
Individual Entrepreneur Maksim Smirnov, TIN 302253987,
Georgia, Tbilisi, Vake district, Zurab Muzashvili str, N5, apt. 2a
1. Generalities
1.1. The personal data processing policy (hereinafter referred to as the «Policy») is published and applied in The limited liability company «Individual Entrepreneur Maksim Smirnov» (hereinafter referred to as the «operator») in accordance with paragraph 2, part 1 of article 18.1 of the Federal law of 27.07.2006 N 152-FZ «Оn personal data».
This Policy defines the procedure and conditions of the Operator in relation to the processing of personal data.
All issues related to the processing of personal data that are not regulated by this Policy are resolved in accordance with the current legislation of the Russian Federation in the field of personal data.
1.2. The purpose of processing personal data is:
· rendering of services for providing access to content owned by the school;
· ensuring the protection of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets;
1.3. Processing is organized by the Operator on the following principles:
· the legality of the purposes and methods of processing personal data, integrity and fairness in the Operator’s activities;
· reliability of personal data, their sufficiency for processing purposes, the inadmissibility of processing personal data that is excessive in relation to the purposes stated when collecting personal data;
· processing only personal data that meet the purposes of processing them;
· compliance of the content and volume of processed personal data with the stated processing goals. The personal data processed must not be excessive in relation to the stated purposes of processing them;
· it is unacceptable to combine databases containing personal data that are processed for purposes that are not compatible with each other;
· ensuring the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of processing personal data. The operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data;
· storing personal data in a form that allows you to identify the subject of personal data for no longer than the purposes of processing personal data required.
1.4. Personal data is processed using automation tools.
1.5. The operator processes the following personal data:
· last name, first name, patronymic
· mobile phone
· registration addresses or current place of residence
· email address
1.5.1. At the same time, some mandatory and/or voluntary personal data, at the personal will of the Platform user, are made publicly available to any third parties by such user in accordance with p.10, p. 1 of article 6 of the Federal law of 27.07.2006 N 152-FZ «Оn personal data».
1.6. When processing personal data, the Operator applies legal, organizational and technical measures to ensure the security of personal data in accordance with article 19 of the Federal law of 27.07.2006 N 152-FZ «Оn personal data», which are enshrined in the provision on ensuring the security of personal data of users of the Platform.
1.7. The operator does not disclose or distribute personal data to third parties without the consent of the personal data subject, except in cases provided for by the current legislation of the Russian Federation and this Policy.
1.8. The assessment of the damage that may be caused to personal data subjects in case of violation by the Operator of the requirements of the Federal law of 27.07.2006 N 152-FZ «On personal data» is determined in accordance with articles 15, 151, 152, 1101 of the Civil code of the Russian Federation. The ratio of this harm to the measures taken by the Operator aimed at preventing, preventing and/or eliminating its consequences is established in School’s documents.
1.9. Conditions for processing personal data by the Operator:
personal data is processed by the Operator after the personal data subject enters into a service contract to use the school’s materials. According to paragraph 5 of article 6 of the Federal law of 27.07.2006 No. 152-FZ «On personal data», the consent of the subject of personal data is not required, since the subject enters into a contract on its own initiative and is the beneficiary of the contract concluded by it.
The operator does not transfer the subject’s personal data to third parties.
1.10. Storage of personal data of subjects who are users of the Platform is carried out in a form that allows you to determine the subject of personal data. Personal data is subject to destruction when the processing goals are reached. Personal data is deleted by deleting an account on the Platform, after which such an account cannot be restored.
1.11. Interaction with Federal Executive authorities on the processing and protection of personal data of subjects whose personal data is processed by the Operator is carried out within the framework of the legislation of the Russian Federation.
1.12. Personal data is processed automatically using computer technology.
2. Responsible for processing personal data
2.1.When processing personal data, the Operator issues a corresponding order appointing a person responsible for processing personal data.
2.2. The person responsible for processing personal data reports to the Operator's Executive body — the General Director, controls the process of processing personal data and ensures the implementation of all the provisions of this Policy that fall within its competence.
2.3. Responsible for processing personal data:
2.3.1. performs internal control over compliance by the Operator and its employees with the legislation of the Russian Federation on personal data, including requirements for personal data protection.
2.3.2. controls the reception and processing of requests and requests from personal data subjects or their representatives.
2.3.3. takes measures to detect unauthorized access to personal data and immediately communicate this information to the General Director.
2.3.4. constantly monitors the level of protection of personal data.
2.3.5. introduces The operator's employees, who have access to personal data, to the provisions of the legislation of the Russian Federation on personal data, including the requirements for personal data protection, as well as local acts of the Operator that determine the procedure for processing personal data.
2.3.6. performs internal control and (or) audit of compliance of personal data processing with the Federal law of 27.07.2006 No. 152-FZ "on personal data" and the regulatory legal acts adopted in accordance with it, the requirements for personal data protection, the Operator's policy regarding personal data processing, and the Operator's local acts.
3. Procedure for ensuring the rights of the personal data subject
3.1. Personal data subjects or their representatives have the rights provided for by the Federal law of 27.07.2006 N 152-FZ «On personal data».
3.2. The operator ensures the rights of personal data subjects in accordance with the procedure established by chapters 3 and 4 of the Federal law of 27.07.2006 N 152-FZ «On personal data».
3.3. The representative’s authority to represent the interests of each personal data subject is confirmed by a corresponding power of attorney.
3.4. The information specified in part 7 of article 22 of the Federal law of 27.07.2006 N 152-FZ «On personal data» is provided to the personal data subject in an accessible form without personal data relating to other personal data subjects, except for cases where there are legal grounds for disclosure of such personal data, in electronic form. At the request of the personal data subject, they can be duplicated on paper. The available form on paper must be certified by the CEO.
3.5. The information specified in part 7 of article 22 of the Federal law of 27.07.2006 N 152-FZ «On personal data» shall be provided to the personal data subject or his representative upon personal request or upon receipt of a request from the personal data subject or his representative. The request must contain the number of the basic document proving the identity of personal data subject or his representative, the date of issuance of the document and the issuing authority, the information confirming the participation of the data subject in relations with the Operator (number of contract, date of conclusion of the contract, conditional verbal designation and/or other information), or information otherwise confirming the fact of processing of personal data by the Operator, the signature of the personal data subject or his representative. If technically possible, the request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
3.6. The right of a personal data subject to access his personal data may be restricted in accordance with Federal laws.
3.7. The operator must immediately terminate the processing of personal data specified in part 1 of article 15 of the Federal law of 27.07.2006 N 152-FZ «On personal data» at the request of the personal data subject.
3.8. The operator is obliged to provide the personal data subject or his representative with the opportunity to get acquainted with the personal data related to this personal data subject at the place of its location during working hours free of charge.
3.9. At the request of the personal data subject or its authorized representative, the operator provides local acts of the Operator concerning the processing of personal data for review. The Operator’s local regulations are the Regulations on processing personal data of Platform users and the Regulations on ensuring the security of personal data of Platform users in accordance with article 19 of the Federal law of 27.07.2006 N 152-FZ «On personal data».