This Privacy Policy for Personal Data (hereinafter referred to as the "Privacy Policy") applies to all information that LLC "Educational Technologies" (hereinafter referred to as the "Company") may obtain about the User during their use of the website smartsad.pro (hereinafter referred to as the "Website"), its services, programs, and products. All rights to the Website are reserved, and their violation is prosecuted in accordance with the legislation of the Russian Federation. The Company cares about the privacy of its Users' data. For these purposes, this Privacy Policy has been developed, including rules for collecting, using, disclosing, transferring, and storing your information.
Use of the Website services constitutes the User's unconditional agreement to this Policy and the conditions of their personal information processing specified herein; in case of disagreement with these terms, the User must refrain from using the services.
1. Terms and Definitions
1.1. In this Privacy Policy, the following terms are used:
- 1.1.1. LLC "Educational Technologies" (hereinafter — "Company") — authorized employees managing the Website, acting on behalf of the Company, who organize and (or) carry out the processing of personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
- 1.1.2. "Personal Data" — any information that the User provides about themselves during registration (creation of an account) or in the process of using the Website, relating directly or indirectly to a specific or identifiable individual (subject of personal data), including data automatically transmitted to the Website services during their use via software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program used to access the services), technical characteristics of the equipment and software used by the User, date and time of access to the services, addresses of requested pages, and other similar information.
- 1.1.3. "Processing of Personal Data" — any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of Personal Data (clause 3, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.4. "Distribution of Personal Data" — actions aimed at disclosing Personal Data to an indefinite circle of persons (clause 5, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.5. "Provision of Personal Data" — actions aimed at disclosing Personal Data to a specific person or a specific circle of persons (clause 6, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.6. "Blocking of Personal Data" — temporary termination of personal data processing (unless processing is necessary to clarify Personal Data) (clause 7, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.7. "Destruction of Personal Data" — actions that make it impossible to restore the content of Personal Data in the information system and (or) result in the destruction of material carriers of Personal Data (clause 8, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.8. "Anonymization of Personal Data" — actions that make it impossible to determine the ownership of Personal Data by a specific User without using additional information (clause 9, article 3 of Federal Law No. 152-FZ of July 27, 2006).
- 1.1.9. "Confidentiality of Personal Data" — a mandatory requirement for the Operator or other person who has gained access to personal data not to allow its distribution without the consent of the subject of Personal Data or another legal basis.
- 1.1.10. "Website User (hereinafter — "User")" — a fully capable individual or legal entity, established and operating in accordance with the legislation of the Russian Federation, registered and having access to the Website via the Internet and using the Website.
- 1.1.11. "Login and Password" — a unique combination of words, numbers, and signs allowing the User to access all features of the Website, including restricted pages of the Platform.
- 1.1.12. "Cookies" — a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server in an HTTP request each time they attempt to open a page of the corresponding website.
- 1.1.13. "IP Address" — a unique network address of a node in a computer network built using the IP protocol.
2. General Provisions
2.1. This Privacy Policy applies to the use of the Website on all computer devices. Use of the Website by the User constitutes agreement to this Privacy Policy and the terms of processing the User's Personal Data. The User is informed and agrees that their consent, given in electronic form on the Website, is a consent that fully meets the requirements of the legislation on Personal Data and allows confirming the fact of its receipt by the Company.
2.2. The Company has the right to periodically make changes to this Privacy Policy. When making changes, the Company notifies the User by posting the current version on the Website.
2.3. This Privacy Policy applies only to the Website; the Company does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website.
2.4. Upon registration on the Website, it is implied that the User provides the Company with accurate information about themselves. The Company is not obliged to verify the accuracy of the provided information.
2.5. By registering on the Website, the User voluntarily and explicitly accepts the terms and conditions of the User Agreement and voluntarily agrees to the processing of their Personal Data in accordance with this Privacy Policy.
2.6. The Company takes necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
2.7. The Company, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.
3. Subject of the Privacy Policy
3.1. This Privacy Policy establishes the Company's obligations for non-disclosure and ensuring a protection regime for the confidentiality of Personal Data that the User provides at the request of the Company when registering on the Website.
3.2. Personal Data permitted for processing under this Privacy Policy is provided by the User by filling out the registration form on the Website.
3.3. The User consents to the processing, including collection, systematization, accumulation, storage, (clarification, update, modification), use, transfer to the Website Administration, anonymization, blocking, destruction, and transfer to third parties of their Personal Data, which, depending on the document (questionnaire, application, feedback, etc.), include but are not limited to the following personal data: User's last name, first name, patronymic; User's photo; User's date of birth; passport data (series, document number, by whom and when issued) of the User; User's city of residence; information about the User's professional activity; User's place of work; User's contact phone number; email address (e-mail); for a legal entity — full name of the legal entity, TIN (INN), PSRN (OGRH), location of the legal entity. This consent is issued without a limitation on its duration.
3.4. The User agrees that the Company collects, stores, and performs other actions to process the User's Personal Information for the following purposes:
- identification of the party within the framework of agreements being concluded;
- provision of personalized services to the User;
- communication with the User, including sending notifications, requests, and information regarding the use of the Website, provision of services, and processing requests from the User;
- improving the quality of the Website, its usability, and developing new services and products;
- conducting statistical and other research based on anonymized data.
3.5. Any other personal information not specified above is subject to storage and non-disclosure, except in cases provided for in clause 5.2 of this Privacy Policy.
3.6. The Company interacts with the User by sending messages, emails, and by other means.
4. Purposes of Processing User's Personal Information
4.1. Processing of special categories of Personal Data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life is not carried out.
4.2. The Company may use the User's Personal Data for the following purposes:
- 4.2.1. Identification of the User registered on the Website to provide access to sections and resources of the Website.
- 4.2.2. Providing the User with access to the Website resources.
- 4.2.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, provision of services, data processing during User registration, and other messages.
- 4.2.4. Creating an account to access sections of the Website.
- 4.2.5. Processing and receiving payments from the Website User.
- 4.2.6. Providing the User with effective technical support in case of problems related to the use of the Website.
5. Methods and Terms of Personal Information Processing
5.1. Processing of the User's personal data is carried out without limitation of duration, by any legal method, including in personal data information systems using automation tools or without using such tools.
5.2. The User's personal data may be transferred to authorized government authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
5.3. The Company takes necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
5.4. The Company, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.
6. Obligations of the Parties
6.1. The User is obliged to:
- 6.1.1. Provide accurate information about Personal Data necessary to use the Website.
- 6.1.2. Update or supplement the provided information about Personal Data in case of changes to this information.
6.2. The Company is obliged to:
- 6.2.1. Use the received information exclusively for the purposes specified in clause 4 of this Privacy Policy.
- 6.2.2. Ensure the confidentiality of the information is kept secret, not disclose it without the User's prior written permission, and not sell, exchange, publish, or disclose by other possible means the transferred personal data of the User, except as provided in clause 5.2 of this Privacy Policy.
- 6.2.3. Block Personal Data relating to the respective User from the moment of request by the User, their legal representative, or an authorized body for the protection of the rights of personal data subjects for the verification period, in case of detection of inaccurate Personal Data or unlawful actions.
7. Liability of the Parties
7.1. If the Company fails to fulfill its obligations, it shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation, except as provided in clauses 5.2 and 7.2 of this Privacy Policy.
7.2. In case of loss or disclosure of Personal Data, the Company is not liable if the data:
- 7.2.1. Became public domain before its loss or disclosure.
- 7.2.2. Was received from a third party before its receipt by the Company.
- 7.2.3. Was disclosed with the consent of the User.
7.3. In case of lack of access to the Website, either fully or partially, due to preventive maintenance or other technical work ensuring the normal functioning of the Website, the Company is not liable to Users for failure to receive any information.
7.4. The User is responsible for any damage that may be caused as a result of using the materials obtained during the use of the Website services.
8. Dispute Resolution
8.1. Before filing a lawsuit in court regarding disputes arising from the relationship between the Website User and the Company, it is mandatory to present a claim (a written proposal for voluntary settlement). All correspondence between the Parties is made in writing, by sending a letter to the email addresses of the Parties: to the Company at info@smartschool.pro, and to the Users at the email specified in the User's account. After receiving the claim, the Party is obliged to provide a written reasoned response to the claim within 15 (fifteen) calendar days.
8.2. If an agreement is not reached, the dispute will be submitted to the competent court in accordance with the current legislation of the Russian Federation.
8.3. This Privacy Policy and the relations between the User and the Website Administration are governed by the current legislation of the Russian Federation.
9. Additional Conditions
9.1. The Company has the right to make changes to this Privacy Policy without the User's consent.
9.2. The modified Privacy Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new edition of the Privacy Policy.
9.3. All suggestions or questions regarding this Privacy Policy should be reported to the Administration through the "Feedback" section.
9.4. The current Privacy Policy is posted on the page at: smartsad.pro