Privacy Policy
for Processing of Personal Data of Smartschool.pro Users
This Personal Data Privacy Policy (hereinafter referred to as the “Privacy Policy”) shall apply to any and all information that OBRAZOVATELNYE TEKHNOLOGII, OOO (hereinafter referred to as the “Company”) may obtain from the User during the use of smartschool.pro website (hereinafter referred to as the “Website”), its services, software, and products. All rights to the Website are reserved; any infringing thereof shall be prosecuted in accordance with the Russian Federation laws. The Company commits to ensure the privacy of its Users’ data. To that end, the Company has developed this Privacy Policy containing the collection, use, disclosure, transfer, and storage rules for your information. By using the Website services, the User expresses their unconditional consent with this Policy and with the User personal data processing as stipulated in this Policy; in case of not consenting to the above, the User shall abstain from using the services.
1. Terms and Definitions.
1.1. The following terms and definitions shall be used herein:
1.1.1. OBRAZOVATELNYE TEKHNOLOGII, OOO (hereinafter referred to as the “Company”) shall mean any and all authorized employees managing the Website and acting on the Company behalf who organize and/or manage the personal data processing and determine the purposes of personal data processing, scope of the personal data to be processed, and actions/operations to be taken with respect to the personal data.
1.1.2. Personal Data shall mean any information concerning the User provided personally by the same when registering/opening a user account or using the Website associated with the said individual/personal data owner, whether directly or indirectly, including any data transferred automatically to the Website services during the use thereof by any software installed on the User device, including, without limitation, IP address, cookies, details of the User browser or any other software used to access the services, technical parameters of the equipment and software used by the User, data and time of access to the services, addresses of requested pages, and any and all other similar information.
1.1.3. Personal Data Processing shall mean any action/operation or a sequence of actions/operations with the Personal Data, whether automated or not, including, without limitation, collection, recording, systematization, accumulation, storage, adjustment/updating/modification, retrieval, use, transfer/dissemination/provision/access, anonymization, blocking, deletion, and destruction of the Personal Data (Clause 3, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.4. Personal Data Dissemination shall mean any and all actions intended to disclose the Personal Data to any indeterminable persons (Clause 5, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.5. Personal Data Provision shall mean any and all actions intended to disclose the Personal Data to a determined party or parties (Clause 6, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.6. Personal Data Blocking shall mean temporary suspension of the Personal Data processing, except where such processing is required to adjust the Personal Data (Clause 7, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.7. Personal Data Destruction shall mean any and all actions rendering the Personal Data impossible to restore in the information system and/or resulting in the destruction of tangible media containing the Personal Data (Clause 8, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.8. Personal Data Anonymization shall mean any and all actions making it impossible to identify the specific User who owns the Personal Data without additional information (Clause 9, Article 3 of Federal Law No. 152-FZ dated July 27, 2006).
1.1.9. Personal Data Privacy shall mean requirements binding for the Processor or any other person gaining access to the personal data that prevent the same from disseminating thereof unless the Personal Data owner has given their consent or it became otherwise legal.
1.1.10. Website User (hereinafter referred to as the “the User”) shall mean a fully competent individual or legal entity established and existing under the Russian Federation laws who has completed registration at, enjoys access to, and uses the Website online.
1.1.11. Login and Password shall mean a unique combination of words, numbers, and characters enabling the User to gain access to all the Website features, including the restricted Platform pages.
1.1.12. Cookies shall mean a small set of data sent by the web server and stored on the User PC that is forwarded to the web server by the web client or web browser in the HTTP request when attempting to open a page of the relevant website.
1.1.13. IP Address shall mean a unique network address of a host using the Internet Protocol. 2. General.
2.1. This Privacy Policy shall apply to the use of the Website on any and all computer devices. By using the Website, the User expresses their consent with this Policy and with the manner of the User Personal Data processing. The User has been duly notified and acknowledges that the consent confirmed at the Website electronically qualifies as their consent fully compliant with the legal requirements of the Personal Data law and constitutes proof that the Company has duly secured such agreement.
2.2. The Company may amend this Privacy Policy from time to time. Upon making the relevant amendments, the Company shall notify the User thereof by posting the effective version on the Website.
2.3. This Privacy Policy shall apply to the Website only; the Company neither controls nor bears any liability for third party websites that the User may access using the links at the Website.
2.4. Registration at the Website relies on the User providing the Company with accurate data of the User. The Company is not responsible for verifying the accuracy of the data provided by the User.
2.5. By registering at the Website, the User voluntarily and expressly accepts the terms and conditions of the User Agreement and voluntarily grants their consent to the processing of the User Personal Data in accordance herewith.
2.6. The Company shall take the necessary organizational and technical measures to protect the User personal information against unauthorized or accidental access, destruction, modification, blocking, copying, dissemination, or any other type of undue actions by any third parties.
2.7. The Company and the User shall take all reasonable efforts to prevent damages or any other adverse effect resulting from the loss or disclosure of the User personal data.
3. Subject Matter of the Privacy Policy.
3.1. This Privacy Policy shall establish the Company obligations not to disclose and to treat confidentially the Personal Data that the User provides at the Company request when registering at the Website.
3.2. The Personal Data that may be processed hereunder shall be provided by the User by filling out the registration form at the Website.
3.3. The User shall grant its consent to the processing, including, inter alia, collection, systematization, accumulation, storage, adjustment/updating/modification, use, transfer to the Website Administration, anonymization, blocking, deletion, destruction, and transfer to any third parties of their Personal Data that will include, depending on the document, which may be a form, application, response, etc., but will not be limited to the following personal data: User last name, first name, and patronymic; User picture; User date of birth; User passport details (document number, issuing authority, and date of issue); User city/town of residence; User professional background; User employer; User contact telephone number; e-mail; for legal entities, the legal entity full business name, INN (Taxpayer Identification Number), OGRN (Primary State Registration Number), legal entity place of business. The consent shall be granted for an indefinite term.
3.4. The User agrees that the Company shall collect, store, and otherwise process the User Personal Information in order to:
• Identify the party of the agreements to be made,
• Provide the User with personalized services,
• Engage in communication with the User, in particular, send notices, requests, and information concerning the use of the Website and provision of services, and process the requests submitted by the User,
• Improve the quality of the Website, make it more user-friendly, develop new functions and services,
• Conduct statistical and other surveys involving anonymized data.
3.5. Any personal information not listed above shall be kept and shall not be subject to disclosure, except as provided otherwise by Clause 5.2. hereof.
3.6. The Company shall communicate with the User by sending messages and e-mail or otherwise.
4. Purposes of Processing the User Personal Information.
4.1. No sensitive Personal Data concerning race, ethnicity, political views, religious or philosophical beliefs, or private life shall be processed.
4.2. The Company may use the User Personal Data in order to:
4.2.1. Identify the User registered at the Website for access to the Website sections and resources.
4.2.2. Provide the User with access to the Website resources.
4.2.3. Exchange information with the User, including, without limitation, by sending notices and requests regarding the use of the Website, provision of services, processing of data upon the User registration or other messages.
4.2.4. Create a user account for accessing the Website sections.
4.2.5. Process and receive payments from the Website User.
4.2.6. Provide the User with efficient technical support in case of any issues associated with the use of the Website.
5. Personal Information Processing Methods and Terms.
5.1. The User personal data shall be processed over an indefinite term by any legal means, including, without limitation, in the personal data information systems, whether automated or not.
5.2. The User personal data may be transferred to competent state authorities of the Russian Federation strictly on the grounds and in the manner prescribed by the Russian Federation laws.
5.3. The Company shall take the necessary organizational and technical measures to protect the User personal information against unauthorized or accidental access, destruction, modification, blocking, copying, dissemination, or any other type of undue actions by any third parties.
5.4. The Company and the User shall take all reasonable efforts to prevent damages or any other adverse effect resulting from the loss or disclosure of the User personal data.
6. Obligations of the Parties.
6.1. The User shall:
6.1.1. Provide accurate information concerning the Personal Data required to use the Website. 6.1.2. Update and supplement the Personal Data provided in case of any changes therein. 6.2. The Company shall:
6.2.1. Use the information received thereby solely for the purposes specified in Clause 4 hereof.
6.2.2. Ensure that confidential information is kept secret, abstain from disclosing the same without the User prior written authorization and from selling, exchanging, publishing, or otherwise disclosing the User personal data provided, except as established otherwise by Clause 5.2. hereof.
6.2.3. Block any and all Personal Data related to the relevant User from the time of contact or request by the User, or their legal representative, or the competent authority that protects the rights of Personal Data owners for the term of verification in case of any discovered inaccurate Personal Data or undue acts.
7. Liability of the Parties.
7.1. Should the Company fail to fulfil obligations, the Company shall be liable for any and all damages suffered by the User due to misuse of the personal data in accordance with the Russian Federation laws, except as established otherwise by Clauses 5.2. and 7.2. hereof.
7.2. The Company shall not be held liable for any loss or disclosure of personal data provided that such personal data:
7.2.1. Became public prior to the respective loss or disclosure.
7.2.2. Were received from a third party prior to receipt by the Company. 7.2.3. Were disclosed with the User consent.
7.3. If the Website cannot be accessed, whether in whole or in part, due to maintenance or any other technical works intended to ensure normal operation of the Website, the Company shall bear no liability to the Users for failure to obtain any information by the latter.
7.4. The User shall be liable for any harm that may be inflicted by the use of materials obtained while using the Website services.
8. Dispute Resolution.
8.1. Prior to taking legal action with respect to any disputes arising from relations between the Website User and the Company, an out-of-court claim/written proposal to settle the dispute amicably shall be delivered at all times. The entire correspondence between the Parties shall be
conducted in writing by e-mailing the Parties at: for the Company, info@smartschool.pro, for the Users, the e-mail addresses given in the User account. Upon receipt of an out-of-court claim, the relevant Party shall provide a written reasoned response to the same within 15 (Fifteen) calendar days.
8.2. If no agreement is reached, the dispute shall be referred to a competent court in accordance with the effective laws of the Russian Federation.
8.3. This Privacy Policy and the relations between the User and the Company shall be governed by the effective laws of the Russian Federation.
9. Miscellaneous.
9.1. The Company may amend this Privacy Policy without the User consent.
9.2. The amended Privacy Policy shall become effective upon its publication on the Website, except as stipulated otherwise by the amended version of the Privacy Policy.
9.3. All proposals or enquiries hereunder shall be submitted to the Administration via the Feedback section.
9.4. The effective Privacy Policy is available at: smartschool.pro