Privacy and personal data processing policy

Russia, Moscow region, Stupino, Russia
Published on the website and entered into force
February 27, 2024

1. GENERAL PROVISIONS

1.1 The policy regarding the processing of personal data (hereinafter - the Policy) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by "Russian Academy of Design" (hereinafter - the Operator).

1.2 The Policy is developed in accordance with paragraph 2, part 2. 1 part 1 of Article 18.1 of the Federal Law of July 27, 2006 № 152-FZ "On Personal Data" (hereinafter - the Federal Law "On Personal Data").

1.3 The Policy contains information subject to disclosure in accordance with Part 1, Article 14, Paragraph 1 of the Federal Law "On Personal Data" and is a publicly available document.


2. INFORMATION ABOUT THE OPERATOR

2.1 The Operator operates at the address 19 Bakhareva St., Stupino, Moscow region.


3. INFORMATION ON PERSONAL DATA PROCESSING

3.1 The Operator processes personal data on a lawful and fair basis in order to fulfill the functions, powers and duties assigned by the legislation, to exercise the rights and legitimate interests of the Operator, the Operator's employees and third parties.

3.2 The Operator receives personal data directly from personal data subjects.

3.3 The Operator processes personal data by automated and non-automated methods, with or without the use of computer facilities.

3.4 Actions of personal data processing include collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.


4. PROCESSING OF CLIENTS' PERSONAL DATA

4.1 The Operator processes personal data of the clients within the framework of the legal relations with the Operator regulated by Part Two of the Civil Code of the Russian Federation No. 14-FZ dated January 26, 1996 (hereinafter referred to as "clients").

4.2 The Operator processes personal data of clients in order to comply with the norms of the legislation of the Russian Federation, as well as for the purpose of:

receiving appeals and applications from the subject of personal data;
inform about new services in the field of additional professional education, special promotions and offers;
conclusion and fulfillment of contractual terms and conditions.

4.3 The Operator processes personal data of clients with their consent, provided by clients and/or their legal representatives by performing conclusory actions on this website, including, but not limited to, making an application, registration in a personal account, subscription to the newsletter, in accordance with this Policy.

4.4 The Operator processes personal data of clients no longer than the purposes of personal data processing require, unless otherwise provided for by the requirements of the legislation of the Russian Federation.

4.5 The Operator may process the following personal data of clients:

Surname, first name, patronymic;
Address;
Contact phone number;
E-mail address.

4.6 Special categories of personal data shall not be processed:

relating to racial, national origin;
political opinions, religious or philosophical beliefs;
health and intimate life.


5. INFORMATION ON PERSONAL DATA SECURITY

5.1 When processing personal data, the Operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.

5.2 Measures to ensure the security of personal data during their processing, applied by the Operator, are planned and implemented in order to ensure compliance with the requirements specified in Article 19 of the Federal Law-152 "On Personal Data".

5.3 In accordance with Article 18.1 of the Federal Law-152, the Operator independently determines the composition and list of measures necessary and sufficient to ensure compliance with the requirements of the legislation. In particular, the Operator has taken the following measures

responsible for organization of personal data processing has been appointed;
developed and implemented local acts on personal data processing, as well as local acts establishing procedures aimed at preventing and detecting violations of the established procedures for personal data processing and eliminating the consequences of such violations;
legal, organizational and technical measures are applied to ensure personal data security in accordance with Article 19 of the Federal Law-152;
internal control of compliance of personal data processing with the Federal Law-152 and legal acts adopted in accordance with it, personal data protection requirements, Operator's policy on personal data processing, local acts of the Operator;
assessment of the damage that may be caused to personal data subjects in case of violation of the Federal Law-152, the correlation between this damage and the measures taken by the Operator to ensure fulfillment of the obligations stipulated by the Federal Law-152;
the Operator's employees directly involved in personal data processing are familiarized with the provisions of the Russian Federation legislation on personal data, including requirements to personal data protection, documents defining the Operator's policy on personal data processing, local acts on personal data processing;
In addition to the requirements of 152-FZ "On Personal Data", the Operator has a set of measures aimed at protection of information about clients, employees and counterparties.


6. RIGHTS OF PERSONAL DATA SUBJECTS

6.1 The subject of personal data has the right to:

to receive personal data relating to this subject and information concerning their processing;
to clarify, block or destroy his/her personal data if they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
to withdraw his/her consent to the processing of personal data;
to protect his/her rights and legitimate interests, including compensation of losses and moral damages in court;
to appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.

6.2 To exercise their rights and legitimate interests, personal data subjects have the right to apply to the Operator or send a request in person or with the help of a representative. The request shall contain the information specified in part 3 of Article 14 of the Federal Law "On Personal Data".