Privacy Policy 

for Processing of Personal Data of 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 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,, 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: