1. INTRODUCTION

1.1. Personal Data Processing Policy (the "Policy") is published and applied by S. F. Firsova, the Sole Proprietor (the “Operator”) in accordance with Paragraph   2 of Part 1 of Art. 18.1 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006.

This Policy defines the procedure and conditions of the Operator in relation to personal data processing, establishes provisions aimed at compliance with the laws of the Russian Federation regarding personal data processing. 

All issues related to personal data processing that are not regulated hereby shall be resolved in accordance with the applicable laws of the Russian Federation in the field of personal data.

2. MAIN PROVISIONS

2.1. The purpose of personal data processing is:

• to provide the subjects of the personal data with the Operator's services. The list of the Operator's services are available at the Internet site of the Operator bonnieandslide.world
• ensuring protection of rights and freedoms of an individual when processing their personal data.

2.2. Processing is arranged by the Operator on the principals:

• legality of the purposes and methods of processing personal data, good faith and fairness of the activities of the Operator;
• reliability of personal data, its sufficiency for the purposes of processing, inadmissibility of processing personal data that is excessive for the purposes stated during the collection of personal data;
•  processing only personal data that meet the purposes of their processing;
• compliance of the content and scope of processed personal data with the declared processing goals. Processed personal data must not be excessive for the stated purposes of their processing;
•  inadmissibility of combining databases containing personal data processing of which is carried out for purposes incompatible with each other;
• ensuring accuracy of personal data, its sufficiency, and, where appropriate, relevance to the purposes of processing personal data. The operator shall take the required measures or have them taken to delete or clarify incomplete or inaccurate data;
• storing personal data in a form that allows you to determine the personal data subject, no longer than the purpose of processing personal data requires so.

2.3. The operator shall process the following personal data:

• name of the personal data subject:
• phone number of the personal data subject;
• email of the personal data subject.

2.4. Personal data specified above are processed with and without automation tools.  When processing personal data without using automation tools, the Operator shall be guided by the Regulation on Characteristics of Non-automated Personal Data Processing, approved by Decree of the Government of the Russian Federation No. 687 dated September 15, 2008.

2.5.  When processing personal data, the Operator shall apply legal, organizational and technical measures to ensure security of personal data in accordance with Art. 19 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006. The operator provides services by hosting its website on the GETCOURSE platform (https://getcourse.ru/), which is a software for organizing the learning process on the Internet. The Platform uses the HTTPS extension to HTTP protocol to support encryption in order to increase security of the website hosted on the Platform.

2.6.  The operator shall not disclose to third parties and shall not distribute personal data without consent of the personal data subject, except as otherwise provided by applicable laws 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 of the requirements of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 by the Operator is determined in accordance with Art. 15, 151, 152, 1101 of the Civil Code of the Russian Federation.

2.7.1. The ratio of the specified harm and the measures taken by the Operator aimed at preventing, avoidance and/or eliminating its consequences shall be determined in accordance with the Federal Law of the Russian Federation No. 152-FZ “On Personal Data” dated July 27, 2006.

2.8. Conditions of personal data processing by the Operator:

1) personal data are processed by the Operator after acceptance of an offer to provide services by the personal data subject.

2) according to Para. 5 of Article 6 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, the personal data subject accepts an offer on their own initiative and is a party and beneficiary under an agreement concluded by them. No separate consent of the personal data subject is required in such a case.

3) terms and conditions of this Policy are available to users in the public domain, until acceptance of the offer for provision of services.

2.9. Storage of users' personal data is carried out in a form that allows determining the personal data subject.

2.10. Personal data is subject to destruction when the purposes of processing have been achieved. Personal data shall be deleted by deleting an account, after which such a record cannot be restored. 

2.11. Relationship with federal executive bodies regarding processing and protection of personal data of subjects whose personal data is processed by the Operator is carried out in accordance with the laws of the Russian Federation.

3. THIRD PARTIES PARTICIPATING IN PERSONAL DATA PROCESSING

3.1. Platforma GETCOURSE LLC (https://getcourse.ru/) INN 7703457361 / KPP 770301001

OGRN 1187746499874, corporate seat: Room 12, Floor 2, Suite I, Bldg 18, 3 Stolyarny Per. Moscow, 123022.

3.2. Hosting and dedicated server services are provided by Selectel LLC https://selectel.ru/about/deta... .

4. PERSON IN CHARGE OF PERSONAL DATA PROCESSING

4.1.   The Operator shall be in charge of personal data processing.

4.2.   The person in charge of personal data processing shall:

4.2.1. exercise internal control over compliance with the laws of the Russian Federation on personal data, including requirements for protection of personal data;

4.2.2. control reception and processing of applications and requests of the subjects of personal data or their representatives;

4.2.3. take measures to detect facts of unauthorized access to personal data;

4.2.4. monitor continuously to ensure the level of security of personal data;

4.2.5. carry out internal control and/or audit of conformity of personal data processing to the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 and regulations adopted in accordance with pursuant to it.

5. PROCEDURE FOR ENSURING THE RIGHTS OF THE SUBJECTS

OF THE PERSONAL DATA BY THE OPERATOR

5.1. Subjects of personal data or their representatives shall have the rights stipulated by the Federal Law  No 152-FZ “On Personal Data” dated July 27, 2006.

5.2. The Operator shall ensure the rights of the subjects of personal data in the manner prescribed by Chapters 3 and 4 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006.

5.3. The authority of the representative to represent the interests of each personal data subject shall be confirmed by the corresponding power of attorney.

5.4. Data indicated in Part 7 of Art. 22 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 shall be provided to the personal data subject in a clear way without personal data relating to other subjects of personal data, unless there are legal grounds for disclosure of such personal data, in e-format.  Under the request of the subject of the personal data the same can be duplicated on paper.

5.5. Data indicated in Part 7 of Art. 22 of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 shall be provided to the personal data subject or their representative when the personal data subject or their representative appear in person or when their request in received. The request shall contain the number of the primary ID document of the personal data subject or their representative, information on the date of issue of the said document and the issuing authority, information confirming participation of the personal data subject in relations with the Operator (agreement number, date of conclusion of the agreement, conventional word mark and/or other information), or information that otherwise confirms the fact that the Operator has processed personal data, signature of the personal data subject or their representative. To the extent technically feasible the request can be sent in the form of an e-document and signed with e-signature in accordance with the laws of the Russian Federation.

5.6. The right of a personal data subject to have 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 personal data subject or their representative the possibility to familiarize themselves with personal data related to this personal data subject at their location during working hours.