1. Introduction

1.1. This Personal Data Processing Policy (hereinafter referred to as the «Policy») is issued and applied by Individual Entrepreneur Evgeny Lvovich Nazarov, Taxpayer Identification Number (INN): 772965005350, Primary State Registration Number (OGRNIP): 323774600477609 (hereinafter referred to as the «Operator») in accordance with Clause 2, Part 1, Article 18.1 of the Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 «On Personal Data.»

1.2. This Policy defines the procedures and conditions under which the Operator processes personal data and establishes provisions aimed at ensuring compliance with the legislation of the Russian Federation regarding personal data processing.

1.3. Any matters related to personal data processing that are not regulated by this Policy shall be governed in accordance with the applicable legislation of the Russian Federation on personal data.

2. Terms and Definitions

2.1. Personal Data — any information relating directly or indirectly to an identified or identifiable individual (the personal data subject).

2.2. Personal Data Operator (Operator) — the entity processing Users’ personal data: Individual Entrepreneur Evgeny Lvovich Nazarov, INN: 772965005350, OGRNIP: 323774600477609.

2.3. Personal Data Processing — any action (operation) or set of actions (operations) performed with personal data with or without the use of automated tools. Personal data processing includes collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, access), blocking, deletion, and destruction.

2.4. Automated Processing of Personal Data — processing of personal data using computer technology.

2.5. Distribution of Personal Data — actions aimed at disclosing personal data to an indefinite number of persons.

2.6. Website — an internet page including all domains, subdomains, pages, their content, as well as related internet services and software.

2.7. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.8. Destruction of Personal Data — actions that make it impossible to restore personal data within personal data information systems and/or actions resulting in the destruction of physical media containing personal data.

3. Purposes of Personal Data Processing

3.1 Purpose No. 1 Identification of the personal data subject for the purpose of concluding and performing a contract under the public offer, including providing and supporting services.

3.1.1 Categories of personal data:
Last name, first name, email address, phone number, age, income, place of residence.

3.1.2 Categories of personal data subjects:
Clients, counterparties.

3.1.3 Legal basis:
Consent of the personal data subject; processing necessary for the performance of a contract concluded under the terms of the offer.

3.1.4 Processing actions:
Collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer, anonymization, deletion, destruction.

3.1.5 Processing method:
Mixed (automated and non-automated).

3.2 Purpose No. 2 Providing feedback to the personal data subject, including processing messages, inquiries, and complaints received from them.

3.2.1 Data categories:
Last name, first name, email address, phone number.

3.2.2 Data subject categories:
Clients, counterparties, website users.

3.2.3 Legal basis:
Consent of the personal data subject; processing necessary for the performance of a contract concluded under the terms of the offer.

3.2.4 Processing actions:
Collection, recording, accumulation, storage, updating, modification, retrieval, use, deletion, destruction.

3.2.5 Processing method:
Mixed.

3.3 Purpose No. 3 Sending notifications, requests, documents, and informational and/or promotional communications to the personal data subject.

3.3.1 Data categories:
Last name, first name, email address, phone number.

3.3.2 Data subject categories:
Clients, counterparties, website users.

3.3.3 Legal basis:
Consent of the personal data subject; processing necessary for the performance of a contract concluded under the terms of the offer.

3.3.4 Processing actions:
Collection, recording, storage, use, transfer, deletion, destruction.

3.3.5 Processing method:
Mixed.

3.4 Purpose No. 4 Publishing and using reviews from personal data subjects to inform other users about the Operator’s services.

3.4.1 Data categories:
Last name, first name.

3.4.2 Data subject categories:
Clients, counterparties.

3.4.3 Legal basis:
Consent of the personal data subject; processing necessary for the performance of a contract concluded under the terms of the offer.

3.4.4 Processing actions:
Collection, storage, use, transfer, anonymization, deletion, destruction.

3.4.5 Processing method:
Mixed.

3.5 Purpose No. 5 Processing refunds to personal data subjects in connection with termination of the contract and settlement of mutual obligations between the parties.

3.5.1 Data categories:
Last name, first name, patronymic, taxpayer identification number (INN), bank account number, passport details.

3.5.2 Data subject categories:
Clients, counterparties.

3.5.3 Legal basis:
Consent of the personal data subject; processing necessary for the performance of a contract concluded under the terms of the offer.

3.5.4 Processing actions:
Collection, recording, systematization, storage, use, transfer, deletion, destruction.

3.5.5 Processing method:
Mixed.

3.6 Purpose No. 6 Interaction with counterparties, including entering into, executing, and administering civil law contracts and maintaining business correspondence.

3.6.1 Data categories:

Last name, first name, patronymic, taxpayer identification number (INN), email address, registered address, phone number, passport details, bank account number.

3.6.2 Data subject categories:
Counterparties and representatives of counterparties.

3.6.3 Legal basis:
Processing necessary for concluding and performing a contract to which the personal data subject is a party.

3.6.4 Processing actions:
Collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer (provision or access), deletion, destruction.

3.6.5 Processing method:
Mixed.

3.7 Purpose No. 7 Analyzing user behavior through cookies, including for statistical and marketing purposes and to improve the user experience when using the Operator’s information resources.

3.7.1 Data categories:
Information collected through analytics tools.

3.7.2 Data subject categories:
Website visitors.

3.7.3 Legal basis:
Consent of the personal data subject.

3.7.4 Processing actions:
Collection, recording, storage, retrieval, use, deletion, anonymization.

3.7.5 Processing method:
Automated.

4. Principles of Personal Data Processing

4.1. Personal data processing is carried out by the Operator in accordance with this Policy, the Operator’s internal regulations, and the legislation of the Russian Federation, including Federal Law No. 152-FZ “On Personal Data.”

4.2. The Operator processes personal data based on the following principles:

• personal data processing is carried out lawfully and fairly;
• processing is limited to specific, predetermined, and legitimate purposes;
• processing incompatible with the purposes of data collection is not permitted;
• databases containing personal data processed for incompatible purposes shall not be merged;
• only personal data relevant to the stated processing purposes shall be processed;
• the content and scope of processed personal data must correspond to the declared purposes and must not be excessive;
• accuracy and relevance of personal data must be ensured; necessary measures must be taken to update or delete inaccurate or incomplete data;
• personal data shall be stored in a form that allows identification of the subject only as long as necessary to achieve the purposes of processing unless a different storage period is established by law or agreement;
• personal data shall be destroyed once the purposes of processing are achieved unless otherwise provided by law;
• personal data processing shall not be used to cause financial or moral harm to data subjects or to restrict their rights and freedoms.

5. Conditions for Personal Data Processing

5.1. Personal data is processed based on acceptance of the public offer by selecting a checkbox on the Website next to wording such as:
“I have read and agree to the terms of the offer,”
or based on consent to personal data processing by selecting a checkbox next to wording such as:
“I have read and agree to the Privacy Policy and consent to the processing of my personal data.”

5.2. The personal data database is located at the Operator’s address:
3 Raspletina Street, Building 3, Apt./Office 35, Moscow, Russian Federation.

5.3. Personal data may be processed by the Operator and by third parties engaged by the Operator or to whom data is transferred in accordance with Russian law, including but not limited to:

5.3.1. GetCourse System LLC (https://getcourse.ru/)
INN: 9731055900 / OGRN: 1197746675170
Address: Skolkovo Innovation Center, Bolshoy Boulevard 42, Building 1, Room 1122, Moscow.

5.3.2. Selectel JSC (https://selectel.ru/)
INN: 7810962785 / OGRN: 1247800067790
Address: 21 Tsvetochnaya Street, Saint Petersburg.

5.3.3. The Operator may engage third parties to process personal data and/or transfer personal data to them without additional consent when required by law, provided that such parties ensure confidentiality and security of personal data. Processing by third parties may occur both with and without automated tools and only under a contract defining the scope of processing, purposes, and security requirements in accordance with Article 19 of the Personal Data Law.

5.4. Processing shall cease upon liquidation of the individual entrepreneur or withdrawal of consent by the personal data subject.

5.5. Data destruction is carried out by deleting the user account and issuing a data destruction report.

6. Use of Cookies and Web Analytics Tools

6.1. Cookies are small text files placed on a user’s device by the Operator’s website or third parties acting on behalf of the Operator. They allow storing information about user actions, preferences, and settings when visiting the website. Cookies may be used to ensure proper functioning of the website, analyze user behavior, and deliver personalized content and advertising.

6.2. By default, visiting and using the website involves the creation and storage of cookies. Users may configure their browser settings to refuse cookies or limit their use; however, some website functions may not operate correctly.

6.3. The website uses the following analytics tools:

7. Personal Data Protection Measures

The Operator implements legal, organizational, and technical measures to protect personal data, including:

• appointment of a person responsible for personal data processing;
• adoption of internal policies and procedures governing personal data processing;
• implementation of security measures required by Article 19 of the Personal Data Law;
• internal monitoring of compliance with personal data legislation;
• risk assessment of potential harm to personal data subjects;
• accounting and secure storage of physical media containing personal data;
• prevention of unauthorized access to premises where personal data is processed;
• use of HTTPS encryption for data transmission on the website.

8. Rights of Personal Data Subjects

Personal data subjects have the right to:

• request information regarding processing of their personal data;
• request correction, deletion, or blocking of inaccurate or unlawfully obtained data;
• object to processing for direct marketing purposes;
• withdraw previously given consent;
• challenge the Operator’s actions administratively or in court.

The Operator does not make decisions based solely on automated processing that produce legal consequences for individuals unless permitted by law or with explicit consent.

For any questions regarding personal data processing or to withdraw consent, contact:
livecontactclub@mail.ru

9. Personal Data Destruction Procedure

Personal data shall be destroyed when processing purposes are achieved or when there is no longer a need for processing, unless otherwise required by law.

Electronic records are destroyed using secure deletion software; paper documents are destroyed using technical shredding equipment; records in databases are deleted by removing the corresponding database entries.

A formal data destruction report is prepared.

10. Final Provisions
10.1. Any disputes shall be resolved in accordance with the legislation of the Russian Federation at the location of the Operator.

10.2. Before filing a lawsuit, the User must submit a written claim to the Operator. The Operator must respond within 10 business days.

10.3. Personal data subjects may exercise their rights or request clarification regarding personal data processing by contacting the Operator via email:

livecontactclub@mail.ru

Operator Details

Individual Entrepreneur
Evgeny Lvovich Nazarov

Tax ID (INN): 772965005350
Primary State Registration Number (OGRNIP): 323774600477609

Email: livecontactclub@mail.ru