1. General Provisions This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by Diana Bukaeva (hereinafter referred to as the Operator).
1.1. The Operator sets the observance of the rights and freedoms of individuals as its most important goal and condition for carrying out its activities in processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website
https://say-privet.com.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases, providing their availability on the Internet at the network address
https://say-privet.com.
2.4. Personal Data Information System - a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data - actions that result in the inability to determine the belonging of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of Personal Data - any action (operation) or set of actions (operations) carried out 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity, or individual, either independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, and actions (operations) performed with personal data.
2.8. Personal Data - any information directly or indirectly related to a specific or determinable User of the website
https://say-privet.com.
2.9. Personal data permitted by the subject of personal data for dissemination - personal data to which unlimited access 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 dissemination in the manner provided by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. User - any visitor to the website
https://say-privet.com.
2.11. Provision of Personal Data - actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.12. Dissemination of Personal Data - any actions aimed at disclosing personal data to an indefinite group of individuals (transferring personal data) or acquainting an unlimited group of individuals with personal data, including publishing personal data in mass media, placing in information and telecommunication networks, or providing 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 the authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data - any actions that result in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- obtain accurate information and/or documents containing personal data from the subject of personal data;
- in case the subject of personal data withdraws consent for the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 obligated to:
- provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
- provide the necessary information to the authorized body for the protection of the rights of subjects of personal data within 30 days from the date of receiving such a request;
- publish or otherwise ensure 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, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unauthorized actions with respect to personal data;
- cease the transmission (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases specified by the Law on Personal Data;
- fulfill other obligations stipulated by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided by federal laws. The 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 in 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 from the operator the clarification of their personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, and also take measures provided by the law to protect their rights;
- impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services on the market;
- withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obligated to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following User's personal data:
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Age.
5.5. Additionally, the website collects and processes depersonalized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.6. The aforementioned data are collectively referred to as Personal Data throughout this Policy.
5.7. The processing of special categories of personal data related to racial or ethnic origin, political views, religious or philosophical beliefs, intimate life, by the Operator is not carried out.
5.8. Processing of personal data allowed for dissemination from the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permissible if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed.
5.9. The User's consent to the processing of personal data allowed for dissemination is provided separately from other consents to the processing of their personal data. In doing so, the conditions specified in Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are determined by the authorized body for the protection of the rights of personal data subjects.
5.9.1. The consent to the processing of personal data allowed for dissemination is directly provided by the User to the Operator.
5.9.2. Within no later than three working days from the moment of receiving the User's consent, the Operator is obliged to publish information about the processing conditions, the presence of prohibitions and conditions for processing personal data allowed for dissemination to an unlimited circle of individuals.
5.9.3. The transfer (dissemination, provision, access) of personal data allowed for dissemination by the personal data subject must be terminated at any time upon the request of the personal data subject. This request must include the surname, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. The specified personal data indicated in this request can only be processed by the Operator to which it is addressed.
5.9.4. The consent to the processing of personal data allowed for dissemination ceases to be valid from the moment the Operator receives the request specified in paragraph 5.9.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. The combination of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that corresponds to the purposes of their processing shall be subject to processing.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or amend incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, where the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of the loss of the need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing User's personal data includes:
- Informing the User through sending electronic emails.
- Providing the User with access to services, information, and/or materials contained on the website https://say-privet.com.
7.2. Additionally, the Operator has the right to send notifications to the User about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at the email address
dialog.lessons@gmail.com with the subject line "Opting out of notifications about new products and services and special offers."
7.3. Depersonalized data of Users collected through internet statistics services are used to collect information about Users' actions on the website, improve the quality of the website, and its content.
8. Legal Bases for Processing Personal Data
8.1. The legal bases for processing personal data by the Operator include:
- The Operator's charter (foundation) documents.
- Agreements concluded between the Operator and the personal data subject.
- Federal laws, other regulatory legal acts in the field of personal data protection.
- Consents of Users for the processing of their personal data, for the processing of personal data allowed for distribution.
8.2. The Operator processes the User's personal data only if they are filled out and/or submitted by the User independently through special forms located on the website
https://say-privet.com or sent to the Operator via email. By filling out the corresponding forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes depersonalized data about the User if allowed by the User's browser settings (enabling the storage of "cookie" files and the use of JavaScript technology).
8.4. The personal data subject independently makes a decision to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions of Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation of functions, powers, and obligations imposed by the legislation of the Russian Federation on the operator.
9.3. Processing of personal data is necessary for the administration of justice, the execution of a court judgment, an act of another authority or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract in which the personal data subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out when the personal data subject has made them publicly available or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transmission, and Other Types of Processing of Personal Data
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 the current legislation in the field of personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. User's personal data will never, under any circumstances, be transferred to third parties, except cases related to the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address
dialog.lessons@gmail.com with the subject line "Updating Personal Data."
10.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by a contract or current legislation.
The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the email address
dialog.lessons@gmail.com with the subject line "Revoking Consent to the Processing of Personal Data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and in a timely manner familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
10.6. Restrictions established by the personal data subject on transfer (except for providing access) or on processing (except for obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data for state, public, and other public interests defined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data during its processing.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary to achieve the purposes of processing the personal data, unless the storage period of personal data is determined by federal law, a contract, or a party to a contract where the personal data subject is a beneficiary or guarantor.
10.9. The termination of processing personal data may occur when the purposes of processing personal data are achieved, the period of consent given by the personal data subject expires, or the personal data subject revokes their consent, as well as when unlawful processing of personal data is detected.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with obtaining and/or transmitting the received information via information and telecommunication networks or without them.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that a foreign state to whose territory the transfer of personal data is supposed to occur provides reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can only be carried out with the written consent of the personal data subject for the cross-border transfer of their personal data and/or the execution of a contract where the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other parties with access to personal data are obligated not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on questions related to the processing of their personal data by contacting the Operator via email at
dialog.lessons@gmail.com.
14.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available on the Internet at the address
https://say-privet.com/confidentiality.