Privacy Policy for Personal Data Processing
This privacy policy for personal data processing is prepared in accordance with the requirements of the Federal Law and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by Alex V., an independent GMAT tutor (hereinafter – the Operator).
1.1. The Operator's most important goal and condition for its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of privacy rights, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.english4work.ru and clients who use the Operator's tutoring services.
2. Basic Concepts 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 processing of personal data (unless processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://https://www.english4work.ru.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User (Client) of the Website or the Operator's tutoring services.
2.10. User / Client – any visitor to the Website or individual using/receiving the Operator's tutoring services.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media of personal data.
3. The Operator’s Rights and Obligations
3.1. The Operator has the right to:
– Receive reliable information and/or documents containing personal data from the subject of personal data.
3.2. The Operator is obliged to:
– Provide the subject of personal data, upon request, with information concerning the processing of their personal data.
– Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.
– Respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.
– Publish or otherwise provide unrestricted access to this Policy on the processing of personal data.
– Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions concerning personal data.
4. Rights and Obligations of Personal Data Subjects (Clients)
4.1. Clients have the right to:
– Receive information regarding the processing of their personal data.
– Require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose.
– Withdraw consent for the processing of personal data.
4.2. Clients are obliged to:
– Provide the Operator with accurate information about themselves.
– Inform the Operator of updates or changes to their personal data.
5. Principles of Personal Data Processing
5.1. Processing is carried out on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes.
5.5. The content and volume of processed data correspond to the stated purposes. Excess data is not processed.
5.7. Data is stored in a form that allows identification of the subject for no longer than required by the processing purposes.
6. Purposes of Personal Data Processing
- Purpose of processing: Providing individual GMAT (Quantitative and Verbal sections) tutoring services, communication with the client, scheduling lessons, processing payments, and analyzing the effectiveness of the teaching methodology.
- Personal data processed:
- surname, first name, patronymic;
- email address;
- phone numbers;
- educational background and GMAT preparation goals;
- progress notes and session feedback.
- Legal basis: The processing is necessary for the performance of a contract to which the client is a party (the agreement for the provision of tutoring services), or to take steps at the request of the client prior to entering into a contract (Article 7.4 of this Policy / 6(1)(b) GDPR analogue).
7.1. Processing is carried out with the consent of the client to the processing of their personal data.
7.4. Processing is necessary for the performance of a contract to which the client is a party, or to take steps at the client's request prior to entering into a contract.
8. Procedure for Collection, Storage, Transfer, and Other Processing of 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 current data protection legislation.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract (e.g., a secure payment processor).
8.3. In case of inaccuracies in personal data, the Client can update them independently by sending a notice to the Operator's email address [vlasov.alex@yahoo.com] with the subject line "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which it was collected. Upon achieving the purposes or if the necessity is lost, personal data is deleted or anonymized.
The Operator has the right to make changes to this Privacy Policy. The new version comes into force from the moment it is posted on the Website (if applicable) or communicated to the Client.