Privacy policy

PROCESSING POLICY
PERSONAL DATA

1. INTRODUCTION
1.1 The Policy of personal data processing (hereinafter - the "Policy") is issued and applied by Limited Liability Company "Soul Software" (INN 2540282018, OGRNIP 1232500034953, (hereinafter - the "Operator") in accordance with paragraph 2, part 2 of Art. 18.1 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data". 1 part 1 of Article 18.1 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data".
This Policy defines the procedure and conditions of the Operator with regard to the processing of personal data, establishes provisions aimed at compliance with the legislation of the Russian Federation concerning the processing of personal data.
All issues related to the processing of personal data not regulated by this Policy shall be resolved in accordance with the current legislation of the Russian Federation in the field of personal data.

2. MAIN PROVISIONS
2.1 The purpose of personal data processing is: provision of services by the Operator on behalf of the personal data subject.
2.2 Processing is organized by the Operator on the principles of:
- legality of the purposes and methods of personal data processing, integrity and fairness in the Operator's activity;
- reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing of personal data that are redundant in relation to the purposes stated in the collection of personal data;
- processing only those personal data that meet the purposes of their processing;
- compliance of the content and scope of processed personal data with the stated processing purposes;
- inadmissibility of combining databases containing personal data processed for incompatible purposes;
- ensuring the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing. The Operator shall take the necessary measures or ensure that they are taken to delete or clarify incomplete or inaccurate data;
- storage of personal data in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing;
- ensuring recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of Russian citizens using databases located in 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 specified above shall be processed with the use of automation means and without the use of automation means. When processing personal data without the use of means of automation, the Operator is guided by the Regulation on the peculiarities of personal data processing carried out without the use of means of automation, approved by the Resolution of the Government of the Russian Federation dated September 15, 2008 N 687.
2.5 When processing personal data, the Operator applies legal, organizational and technical measures to ensure personal data security in accordance with Article 19 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data".
The Operator provides services by placing its website at https://getcourse.ru/, which is a software "GETCourse 2.0.", designed to create an online school and organize the learning process in the Internet. The getcourse.ru website uses HTTPS extension to the HTTP protocol in order to increase the security and protection of information.
2.6 The operator does not disclose to third parties and does not distribute personal data without the consent of the subject of personal data, except in cases provided for by the current legislation of the Russian Federation and this Policy.
2.7. The assessment of damage that may be caused to the subjects of personal data in case of violation by the Operator of the requirements of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data" is determined in accordance with Art. 15, 151, 152, 1101 of the Civil Code of the Russian Federation.
2.7.1 The correlation between the said damage and the measures taken by the Operator aimed at prevention, avoidance and/or elimination of its consequences shall be determined in accordance with the Federal Law of the Russian Federation dated 27.07.2006 N 152-FZ "On Personal Data".
2.8 Conditions of personal data processing by the Operator:
1) personal data are processed by the Operator after the personal data subject accepts the offer for services.
2) according to Article 6, paragraph 5 of the Federal Law dated 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 contract concluded by him/her. A separate consent to the processing of the subject's personal data is not required in such case.
3) the terms and conditions of this Policy are available to users in the public domain, until the acceptance of the offer for the provision of services.
2.9 The storage of personal data of users is carried out in a form that allows to identify the subject of personal data.
2.10. Personal data are subject to destruction upon achievement of the processing purposes. Deletion of personal data is carried out by deleting the account, after which such record cannot be restored.
2.11. Interaction with federal executive authorities on the issues of processing and protection of personal data of the subjects whose personal data are 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. Sistema GETKURS LLC (https://getcourse.ru/) TIN 9731055900 / KPP 773101001, OGRN 1197746675170, location: 121596, Moscow, Gorbunova Street, 2, building 3, room 3.
1.3.2 Hosting services and dedicated server services are provided by LLC "Selektel" https://selectel.ru/about/details.

4. RESPONSIBLE FOR PERSONAL DATA PROCESSING
4.1 Responsible for personal data processing is the Operator or its legal representative.
4.2. The person responsible for personal data processing:
4.2.1.exercises internal control over compliance with the legislation of the Russian Federation on personal data, including requirements for personal data protection;
4.2.2.controls the receipt and processing of appeals and requests of personal data subjects or their representatives;
4.2.3. take measures to detect the facts of unauthorized access to personal data;
4.2.4. carries out permanent control over ensuring the level of personal data protection;
4.2.5. performs internal control and (or) audit of compliance of personal data processing with the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data" and the regulations adopted in accordance with it.

5. PROCEDURE FOR ENSURING THE RIGHTS OF PERSONAL DATA SUBJECTS BY THE OPERATOR
5.1 Personal data subjects or their representatives have the rights provided by the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data".
5.2 The Operator shall ensure the rights of personal data subjects in the manner prescribed by Chapters 3 and 4 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data".
5.3 The authority of the representative to represent the interests of each personal data subject shall be confirmed by a power of attorney.
5.4 The information specified in part 7 of Article 22 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data" shall be 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 disclosure of such personal data, in electronic form. At the request of the personal data subject, they may be duplicated on paper.
5.5 The information specified in part 7 of Article 22 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data" shall be provided to the personal data subject or his/her representative upon personal contact or upon receipt of a request from the personal data subject or his/her representative. The request shall contain the number of the main identity document of the personal data subject or his/her representative, information on the date of issue of the said document and the issuing authority,
information confirming the personal data subject's participation in relations with the Operator (contract number, date of contract conclusion, conventional word designation and (or) other information), or information otherwise confirming the fact of personal data processing by the Operator, signature of the personal data subject or his/her representative. If technically possible, the request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
5.6 The right of the subject of personal data to access his/her personal data may be restricted in accordance with federal laws.
5.7. The Operator shall be obliged to provide the personal data subject or his/her representative with the opportunity to familiarize with personal data related to this personal data subject at its location during working hours, free of charge.