Varganova E.

December 19, 2022

Personal Data Processing Policy

1. General provisions


This Personal Data Processing Policy is compiled in accordance with the requirements of the Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 and defines the procedure for processing personal data and the measures to ensure the personal data security taken by Varganova Ekaterina Sergeevna (hereinafter referred to as the Operator).


1.1. The Operator sets the observance of rights and liberties of a person while processing his/her personal data, including the right to privacy, personal and family secrecy, as the most important goal and condition for implementation of activities.


1.2. This Operator's policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information about https://school.lakomka-zaika.com website visitors that the Operator can obtain.


2. Basic terms used in the Policy


2.1. Automated personal data processing – processing of personal data by means of computer technology;


2.2. Blocking of personal data – temporary cessation of personal data processing (except for the cases when the processing is needed for personal data specification);


2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://school.lakomka-zaika.com;


2.4. Personal data information system — a database that contains personal data as well as information technologies and hardware used for data processing;


2.5. Anonymization of personal data – actions performed on personal data that do not permit the identity of the individual or other personal data subject concerned to be verified solely from such anonymized data;


2.6. Personal data processing – any action (operation) or a combination of actions (operations) performed both automatically and manually on personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data;


2.7. Operator – state agency, municipal authority, legal entity or individual who independently or in cooperation with other entities organizes and/or processes personal data as well as determines the purposes and scope of personal data processing, and the actions (operations) performed on personal data;


2.8. Personal data – any information referring directly or indirectly to a particular or identified User of the https://school.lakomka-zaika.com website;


2.9. User – any visitor to the https://school.lakomka-zaika.com​ website;


2.10. Provision of personal data – actions related to making the data available to a definite person or a definite range of persons;


2.11. Distribution of personal data – actions related to making the data available to indefinite range of persons (personal data transfer), including publication of personal data in the mass media and information and telecommunications networks or providing access to personal data in any other way;


2.12. Cross–border transfer of personal data – cross-border transfer of personal data to a foreign state agency, foreign legal entity or individual located in a foreign state.


2.13. Destruction of personal data – actions performed on personal data that prevent such data from being restored in the information system and (or) actions of physical destruction aimed at the tangible medium of personal data;


3.1 The Operator may process the following personal data of the User:

  • Electronic mail address;
  • Phone numbers;
  • Name;

3.2. Also, anonymous data about visitors (including cookies) are collected and processed on the Website using web analytics services (Yandex Metrica, Google Analytics and others).


3.3. The above terms further in the Policy text are combined by the general concept of Personal Data.


4. Purposes of personal data processing


4.1. The purpose of the User's personal data processing is to provide the User with access to the services, information and/or materials contained on the Website.


4.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending to the Operator’s address support@lakomka-zaika.com an email marked as «Refusal of notifications about new products, services and special offers».


4.3. Anonymous User’s data collected using web analytics services are used to collect information about User’s actions on the Website in order to improve the Website quality and content.


5. Legal grounds for personal data processing


5.1. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the https://school.lakomka-zaika.com website. By filling in the appropriate forms and/or sending his/her personal data to the Operator, the User agrees with this Policy.


5.2. The Operator processes anonymous data about the User if this is allowed in the User’s browser settings (the saving of cookies and the use of JavaScript technology are enabled).


6. The procedure for collection, storage, transfer and other types of personal data processing.

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.


6.1. The Operator ensures personal data safety and takes all possible measures to exclude unauthorized access to personal data.


6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to implementation of current legislation.


6.3. In case of finding inaccuracies in the personal data, the User can update them independently by sending to the Operator’s email address support@lakomka-zaika.com a notification marked as «Updating of personal data».


6.4. The period of personal data processing is unlimited. The User can withdraw his/her consent to the personal data processing any time by sending to the Operator’s email address support@lakomka-zaika.com a notification marked as «Withdrawal of consent to personal data processing».


7. Cross-border transfer of personal data


7.1. Prior to the start of cross-border transferring of personal data, the Operator is obliged to make sure that the foreign state to which territory the personal data are being transferred provides reliable protection of the rights of personal data subjects.


7.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can only be carried out if the personal data subject gives a written consent for the cross-border transfer of his/her personal data and/or the execution of the contract to which the personal data subject is a party.


8. Final provisions


8.1. The User can get any clarifications on issues of interest concerning the processing of his/her personal data by contacting the Operator via email support@lakomka-zaika.com.


8.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.