Personal data processing policy

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Misakyan Elena Vyacheslavovna (hereinafter referred to as the Operator). 1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing his personal data, in including the protection of the rights to privacy, personal and family secrets. 1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://ycla-coding.com/.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

2.2. Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website is a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://ycla-coding.com/.

2.4. Personal data information system is a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data by a specific User or another subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a government agency, a municipal agency, a legal entity or an individual, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information related directly or indirectly to a specific or determinable User of the website https://ycla-coding.com/.

2.9. Personal data permitted by the subject of personal data for distribution are personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).

2.10. User is any visitor to the website https://ycla-coding.com/.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing an unlimited group of persons with personal data, including disclosure of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoring the contents of personal data in the personal data information system and (or) the physical carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:

• to receive reliable information and/or documents containing personal data from the personal data subject;
• if the personal data subject revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on personal data or other federal laws.

3.2. The operator is obliged to:

• provide the personal data subject, at his request, with information regarding the processing of his personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on personal data;
• notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 30 days from the date of receipt of such request;
• publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
• take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
• stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
• fulfill other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
• demand that the operator clarify their personal data, block them or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
• to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
• to revoke consent to the processing of personal data;
• to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against the illegal actions or inaction of the Operator when processing his personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about themselves;
• notify the Operator about clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Telephone numbers.

5.4. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others).

5.5. The above data are further united in the text of the Policy under the general concept of Personal Data.

5.6. The Operator does not process special categories of personal data related to racial, national origin, political views, religious or philosophical beliefs, or intimate life.

5.7. Processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data, is permitted if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data are observed.

5.8. The User's consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of his personal data. In this case, the conditions stipulated, in particular, by Art. 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.

5.8.2 The Operator is obliged, no later than three working days from the moment of receiving the specified consent of the User, to publish information on the processing conditions, the existence of prohibitions and conditions for the processing of personal data by an unlimited number of persons, permitted for distribution.

5.8.3 Transfer (dissemination, provision, access) of personal data permitted for dissemination by the subject of personal data shall be terminated at any time upon request of the subject of personal data. This request shall include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.8.4 Consent to the processing of personal data permitted for dissemination shall cease to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. Personal data shall be processed on a lawful and fair basis.

6.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. It is not allowed to process personal data in a way that is incompatible with the purposes of collecting the personal data.

6.3. It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.

6.4. Only personal data that meet the purposes of their processing may be processed.

6.5. The content and volume of the personal data being processed correspond to the stated purposes of processing. It is not allowed to process personal data in excess of the stated purposes of their processing.

6.6. When processing personal data, the accuracy of the personal data, their sufficiency and, where necessary, relevance in relation to the purposes of processing the personal data are ensured. The operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows to identify the subject of personal data, for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The personal data being processed shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User's personal data:

• informing the User by sending e-mails;
• conclusion, execution and termination of civil contracts;
• providing the User with access to services, information and/or materials contained on the website https://ycla-coding.com/.

7.2. 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 the Operator a letter to the e-mail address support@ycla-coding.com with the subject line "Refusal to receive notifications about new products and services and special offers".

7.3. Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

• agreements concluded between the operator and the subject of personal data;
• federal laws, other regulatory legal acts in the field of protection of personal data;
• consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. 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 website https://ycla-coding.com/ or sent to the Operator by e-mail. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.

8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (saving cookies and using JavaScript technology are enabled).

8.4. The subject of personal data independently decides on providing his personal data and gives consent freely, of his own free will and in his own interests.

9. Terms of personal data processing

9.1. Personal data is processed with the consent of the subject of personal data to the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of an agreement, a party to which, or a beneficiary or guarantor under which the subject of personal data is a personal data subject, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the subject of personal data will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

9.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for collecting, storing, transferring and otherwise processing personal data

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

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

10.3. In case of detection of inaccuracies in personal data, the User can update them independently, by sending the Operator a notification to the Operator's e-mail address support@ycla-coding.com with the subject "Update of personal data".

10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The User may at any time revoke his consent to the processing of personal data by sending the Operator a notification via e-mail to the Operator's e-mail address support@ycla-coding.com with the subject "Revocation of consent to the processing of personal data".

10.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User are obliged to independently and promptly familiarize themselves with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in state, public and other public interests, determined by the legislation of the Russian Federation.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The operator shall store personal data in a form that allows the subject of personal data to be identified for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-border transfer of personal data

12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory it is proposed to transfer the personal data ensures reliable protection of the rights of the subjects of personal data.

12.2. Cross-border transfer of personal data in the territory of foreign states that do not meet the above requirements may be carried out only in the case of the presence of written consent of the subject of personal data to the cross-border transfer of his/her personal data and/or the execution of an agreement to which the subject of personal data is a party.

13. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

14. Final provisions

14.1. The User may obtain any clarifications on questions of interest regarding the processing of his/her personal data by contacting the Operator by e-mail at support@ycla-coding.com.

14.2. 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.

14.3. The current version of the Policy is freely available on the Internet at https://ycla-coding.com/.