PERSONAL DATA PROCESSING POLICY1. INTRODUCTION 1.1. The personal data processing policy (hereinafter referred to as the "Policy") has been issued and applied by IP Kanakin Andrey Anatolyevich (TIN 774316420316, Primary State Registration Number (OGRN) 31377461540751) (hereinafter referred to as the "Operator") in accordance with sub-paragraph 2 of paragraph 1 of Article 18.1 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data".This Policy defines the procedure and conditions of the Operator in relation to the processing of personal data, establishes provisions aimed at compliance with the legislation of the Russian Federation regarding the processing of personal data.All issues related to the processing of personal data 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 on behalf of the subject of personal data.
2.2. The processing is organized by the Operator on the following principles:
• legality of the purposes and methods of processing personal data, good faith and fairness in the activities of the Operator;
• reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing personal data that are redundant in relation to the purposes stated when collecting personal data;
• processing only those personal data that meet the purposes of their processing. The processed personal data should not be redundant in relation to the stated purposes of their processing;
• compliance of the content and volume of processed personal data with the stated processing objectives.
• inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• ensuring the accuracy of personal data, their sufficiency, and, if necessary, 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;
• storing personal data in a form that allows you to determine the subject of personal data, no longer than required by the purpose of processing personal data;
• ensuring the recording, systematization, accumulation, storage, clarification (updating, changes), 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, surname of the subject of personal data;
• telephone number of the subject of personal data;
• e-mail of the subject of personal data.
2.4. The personal data indicated 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 without using automation tools, approved by the Decree of the Government of the Russian Federation of 15 September 2008 N 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 the Federal Law of 27.07.2006 N 152-FZ "On Personal Data". The Operator provides services by posting its website on the website
https://getcourse.ru/, which is the GETKURS 2.0 software designed to create an online school and organize the learning process on the Internet. The getcourse.ru website uses the HTTPS extension to the HTTP protocol in order to improve the security and protection of information.
2.6. The Operator does not disclose to third parties and does not distribute personal data without consent of the subject of personal data, except in the cases provided for by the current legislation of the Russian Federation and this Policy.
2.7. Assessment of harm that may be caused to subjects of personal data in case of violation by the Operator of requirements of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" is determined in accordance with Articles 15, 151, 152, 1101 of the Civil Code of the Russian Federation.
2.7.1. The ratio of this harm and the measures taken by the Operator aimed at preventing, avoiding and/or eliminating its consequences is determined in accordance with the Federal Law of the Russian Federation of 27.07.2006 N 152-FZ "On Personal Data".
2.8. Conditions for processing personal data by the Operator:
• personal data is processed by the Operator after acceptance of the offer for provision of services by the subject of personal data.
• in accordance with paragraph 5 of Article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", the subject of personal data accepts the offer on his/her own initiative and is a party and beneficiary under the agreement concluded by him/her. In this case, a separate consent to the processing the personal data of the subject is not required.
• terms of this Policy are available to users in the public domain, until the acceptance of the offer for the provision of services.
2.9. Storage of personal data of users is carried out in a form that allows you to determine the subject of personal data.
2.10. Personal data is subject to destruction upon achievement of the processing objectives. The deletion of personal data is carried out by deleting the account, after which such a record cannot be restored.
2.11. Interaction with federal executive authorities on the processing and protection of personal data of subjects whose personal data is 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. "System GETCOURSE" LLC (
https://getcourse.ru/)
TIN: 9731055900
CRR: 773101001
PSRN: 1197746675170
LOCATION: 121596, Moscow, 2 Gorbunova street, Building 3, Room 3.
3.2. Hosting services and dedicated server provision services are provided by "Selectel" LLC
https://selectel.ru/about/details.
4. PERSON RESPONSIBLE FOR PROCESSING OF PERSONAL DATA 4.1. The Operator or their legal representative is the person responsible for processing of personal data.
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 requirements for the protection of personal data;
4.2.2. Controls receipt and processing of appeals and requests from subjects of personal data or their representatives;
4.2.3. Takes measures to detect facts of unauthorized access to personal data;
4.2.4. Carries out constant control over ensuring the level of protection of personal data;
4.2.5. Carries out internal control and (or) audit of the compliance of personal data processing with the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" and the regulatory legal acts adopted in accordance with it.
5. PROCEDURE FOR PROVIDING THE RIGHTS OF THE PERSONAL DATA SUBJECT BY THE OPERATOR 5.1. Subjects of personal data or their representatives have the rights provided for by the Federal Law of 27.07.2006 N 152-FZ "On Personal Data".
5.2. The Operator ensures the rights of subjects of personal data in the manner prescribed by chapters 3 and 4 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data'.
5.3. The representative's authority to represent the interests of each subject of personal data is confirmed by the appropriate power of attorney.
5.4. The information specified in paragraph 7 of Article 22 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" is provided to the subject of personal data in an accessible form, without personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data, in electronic format. At the request of the subject of personal data, they can be duplicated on paper.
5.5. The information specified in paragraph 7 of Article 22 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" is provided to the subject of personal data or their representative upon personal appeal or upon receipt of a request from the subject of personal data or their representative. The request must contain the number of the main document proving the identity of the subject of personal data or their representative, information about the date of issue of the specified document and the issuing authority, information confirming the participation of the subject of personal data in relations with the Operator (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator, the signature of the subject of personal data or their representative. If technically feasible, the request can be sent in the form of an electronic document and signed with electronic signature in accordance with the legislation of the Russian Federation.
5.6. The right of the subject of personal data to access their personal data may be limited in accordance with federal laws.
5.7. The Operator is obliged to provide, free of charge, to the subject of personal data or their representative the opportunity to familiarize themselves with the personal data relating to this subject of personal data at their place of location during working hours.