Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data,” and outlines the procedures for processing personal data and measures to ensure the security of personal data for LLC “Education, Consulting, and Expertise Center ‘Butterfly’” represented by the General Director, Margarita Nikolaevna Boiko (hereinafter referred to as the Operator).
1.1 The Operator’s primary goal and condition for carrying out its activities is to ensure the respect for human and citizen rights and freedoms during the processing of personal data, including the protection of the right to privacy, and personal and family secrets.
1.2 This Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website http://studying-in-russia.ru/.
2. Key Terms Used in the Policy
2.1 Automated Processing of Personal Data – processing of personal data using computer technology.
2.2 Blocking of Personal Data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
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 web address http://studying-in-russia.ru/.
2.4 Personal Data Information System – a set of personal data contained in databases, along with the information technologies and technical means that ensure their processing.
2.5 Anonymization of Personal Data – actions that make it impossible to identify the specific User or other personal data subject without using additional information.
2.6 Processing of Personal Data – any action (operation) or set of actions (operations) performed with personal data, whether or not using automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7 Operator – a government authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with the personal data.
2.8 Personal Data – any information related directly or indirectly to a specific or identifiable User of the website http://studying-in-russia.ru/.
2.9 User – any visitor to the website http://studying-in-russia.ru/.
2.10 Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.11 Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite group of individuals (such as transferring personal data) or making personal data accessible to an unlimited audience, including publishing personal data in the media, placing it on information and telecommunication networks, or providing access to personal data in any other way.
2.12 Cross-Border Transfer of Personal Data – the transfer of personal data to the territory of a foreign country to a foreign governmental authority, foreign individual, or foreign legal entity.
2.13 Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in the personal data information system, and/or the destruction of physical media containing personal data.
3. The Operator may process the following personal data of the User:
3.1 Last name, first name, middle name;
3.2 Email address;
3.3 Phone numbers;
3.4 Year, month, day, and place of birth;
3.5 Passport details (passport series, number, issuing authority, and date of issuance);
3.6 Photographs;
3.7 The website also collects and processes anonymized data about visitors (including cookies) using web analytics services (such as Yandex Metrica, Google Analytics, and others).
3.8 And any other data with the User’s consent.
The aforementioned data are collectively referred to as Personal Data throughout this Policy.
4. Purposes of Personal Data Processing
4.1 The purpose of processing the User’s personal data is to inform the User by sending emails and to provide the User with access to services, information, and/or materials available on the website.
4.2 The Operator also reserves the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to support@studying-in-russia.ru with the subject line “Unsubscribe from notifications about new products and services and special offers.”
4.3 Anonymized data collected from Users through web analytics services is used to gather information about User activities on the site, improve the quality of the site, and its content.
5. Legal Grounds for Processing Personal Data
5.1 The Operator processes the User’s personal data only if the User independently fills out and/or submits it through the special forms available on the website http://studying-in-russia.ru/. By completing the relevant forms and/or submitting their personal data to the Operator, the User agrees to this Policy.
5.2 The Operator processes anonymized data about the User if allowed by the User’s browser settings (such as enabling the storage of cookies and the use of JavaScript technology).
6. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data
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 the protection of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized individuals.
6.2 The User’s personal data will never be transferred to third parties under any circumstances, except as required by applicable law.
6.3 If inaccuracies are found in the personal data, the User may update it themselves by sending a notification to the Operator at support@studying-in-russia.ru with the subject line “Update of Personal Data.”
6.4 The period for processing personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at support@studying-in-russia.ru with the subject line “Withdrawal of Consent to Process Personal Data.”
7. Cross-Border Transfer of Personal Data
7.1 Before initiating any cross-border transfer of personal data, the Operator must ensure that the foreign country to which the data is to be transferred provides adequate protection for the rights of personal data subjects.
7.2 Cross-border transfer of personal data to foreign countries that do not meet the aforementioned requirements may only occur if there is written consent from the data subject for the cross-border transfer of their personal data and/or if it is necessary for the performance of a contract to which the data subject is a party.
8. Final Provisions
8.1 The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at support@studying-in-russia.ru.
8.2 Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
8.3 The current version of the Policy is freely accessible on the internet at http://studying-in-russia.ru/policy-en.