OGRNIP 319784700172711
INN 511300459904
IP Lesun V. V.
October 1, 2024
Personal Data Processing Policy
1. INTRODUCTION
1.1. The Personal Data Processing Policy (hereinafter referred to as the "Policy") is issued and applied by IP Lesun V.V. (hereinafter referred to as the "Operator") in accordance with clause 2, part 1, article 18.1 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data". This Policy defines the procedure and conditions of the Operator regarding the processing of personal data and establishes provisions aimed at compliance with the legislation of the Russian Federation concerning 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.
2. BASIC PROVISIONS
2.1. The purpose of processing personal data is: the provision of services by the Operator at the request of the personal data subject.
2.2. The processing is organized by the Operator based on the principles of:
• legality of the purposes and methods of processing personal data, good faith, and fairness in the Operator's activities;
• accuracy of personal data, their sufficiency for the purposes of processing, and the inadmissibility of processing personal data that are excessive in relation to the purposes stated at the time of collection;
• processing only those personal data that meet the purposes of their processing. The processed personal data should not be excessive in relation to the stated purposes of their processing;
• correspondence of the content and scope of the processed personal data to the stated purposes of processing;
• inadmissibility of combining databases containing personal data, the processing of which is carried out for incompatible purposes;
• ensuring the accuracy of personal data, their sufficiency, and, if necessary, their relevance in relation to the purposes of processing personal data. The Operator takes the necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate data;
• storage of personal data in a form that allows the personal data subject to be identified, no longer than required by the purposes of processing personal data;
• ensuring the recording, systematization, accumulation, storage, clarification (updating, changing), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
2.3. The Operator processes the following personal data:
• name and surname of the personal data subject;
• phone number of the personal data subject;
• email address of the personal data subject.
2.4. The personal data mentioned above are processed using automation tools and without using automation tools. When processing personal data without using automation tools, the Operator is guided by the Regulation on the specifics of processing personal data carried out without using automation tools, approved by the Resolution of the Government of the Russian Federation dated September 15, 2008, No. 687.
2.5. 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 Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data". The Operator provides services through the placement of its website on the site https://getcourse.ru/, which is the software "GETCOURSE 2.0.", designed to create an online school and organize the educational process on the Internet. The site getcourse.ru uses the HTTPS extension to the HTTP protocol to enhance security and protect information.
2.6. 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.
2.7. The assessment of the harm that may be caused to the personal data subjects in the event of a violation by the Operator of the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" is determined in accordance with Articles 15, 151, 152, and 1101 of the Civil Code of the Russian Federation.
2.7.1. The relationship between the specified harm and the measures taken by the Operator to prevent, avoid, and/or eliminate its consequences is determined in accordance with Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data".
2.8. Conditions for the processing of personal data by the Operator:
personal data are processed by the Operator after the acceptance by the personal data subject of the offer to provide services.
in accordance with clause 5 of Article 6 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data", the personal data subject accepts the offer on their own initiative and is a party and beneficiary under the concluded contract. Separate consent to the processing of the personal data subject's personal data is not required in this case.
the conditions of this Policy are available to users in open access before the acceptance of the offer to provide services.
2.9. The storage of personal data of users is carried out in a form that allows the personal data subject to be identified.
2.10. Personal data are subject to destruction upon achievement of the processing purposes. The deletion of personal data is carried out by deleting the account, after which such a record is not subject to recovery.
2.11. Interaction with federal executive authorities on issues of processing and protection of personal data of subjects, whose personal data are processed by the Operator, is carried out within the framework of the legislation of the Russian Federation.
3. THIRD PARTIES INVOLVED IN THE PROCESSING OF PERSONAL DATA
3.1. LLC "System GETCOURSE" (https://getcourse.ru/) INN 9731055900 / KPP 773101001, OGRN 1197746675170, location: 121596, Moscow, Gorbunova Street, house 2, building 3, room 3.
3.2. Hosting services and dedicated server services are provided by LLC "Selectel" https://selectel.ru/about/details.
4. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
4.1. The person responsible for the processing of personal data is the Operator or its legal representative.
4.2. The person responsible for the processing of personal data:
4.2.1. carries out internal control over compliance with the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data;
4.2.2. controls the receipt and processing of appeals and requests from personal data subjects or their representatives;
4.2.3. takes measures to detect facts of unauthorized access to personal data;
4.2.4. conducts constant control over the provision of the level of protection of personal data;
4.2.5. carries out internal control and (or) audit of the compliance of the processing of personal data with Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" and the normative legal acts adopted in accordance with it.
5. PROCEDURE FOR ENSURING THE RIGHTS OF THE PERSONAL DATA SUBJECT BY THE OPERATOR
5.1. Personal data subjects or their representatives have the rights provided for by Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data".
5.2. The Operator ensures the rights of personal data subjects in the manner established by Chapters 3 and 4 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data".
5.3. The authority of the representative to represent the interests of each personal data subject is confirmed by the relevant power of attorney.
5.4. The information specified in clause 7 of Article 22 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" is provided to the personal data subject in an accessible form without personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data, in electronic form. At the request of the personal data subject, they can be duplicated on paper.
5.5. The information specified in clause 7 of Article 22 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" is provided to the personal data subject or their representative upon personal appeal or upon receipt of a request from the personal data subject or their representative. The request must contain the number of the main document certifying the identity of the personal data subject or their representative, information about the date of issue of the said document and the issuing authority, information confirming the participation of the personal data subject in relations with the Operator (contract number, contract date, conditional verbal designation and (or) other information), or information otherwise confirming the fact of processing personal data by the Operator, the signature of the personal data subject or their representative. If there is a technical possibility, 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.
5.6. The right of the personal data subject to access their personal data may be restricted in accordance with federal laws.
5.7. The Operator must provide the personal data subject or their representative with the opportunity to familiarize themselves with the personal data relating to this personal data subject free of charge at the location of the Operator during working hours.
6. ADDITIONAL PROVISIONS
6.1. This document has been executed in Russian and English languages. In the event of any discrepancy between the English and the Russian versions of this Personal Data Processing Policy the Russian text shall prevail.