1. General Provisions

This policy for processing personal data is drafted 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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by Unistudy-FZE (hereinafter referred to as the "Operator").
1.1. The Operator considers compliance with the rights and freedoms of the individual as the most important goal and condition of its activities when processing personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Policy on processing personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://unistudy.me.

1. Basic terms 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 suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as computer programs and databases that provide their accessibility on the internet at the network address https://unistudy.me.
2.4. Personal data information system - a set of personal data contained in databases, which ensures their processing with information technology and technical means.
2.5. Depersonalization of personal data - actions that make it impossible to determine the belonging of personal data to a specific user or other subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with personal data using automation or without using such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator is a state authority, municipal authority, legal or natural person who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, the actions (operations) carried out with personal data.
2.8. Personal data is any information directly or indirectly related to a specific or identifiable User of the website https://unistudy.me.
2.9. Personal data permitted by the data subject for dissemination are personal data, access to which by an unlimited number of persons is provided by the data subject by giving consent to the processing of personal data permitted for dissemination in the manner provided by the Law on Personal Data (hereinafter - personal data permitted for dissemination).
2.10. User is any visitor of the website https://unistudy.me.
2.11. Provision of personal data is actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data is any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or allowing an unlimited number of persons to access personal data, including publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to a foreign government agency, foreign individual or foreign legal entity.
2.14. Destruction of personal data is any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the contents of personal data in the personal data information system and/or material carriers of personal data are destroyed.
2.15. Cookies - are files or pieces of information that may be stored on your computer (or other Internet-compatible devices such as a smartphone or tablet) when you visit a website and/or use a mobile application. This type of file typically contains the name of the website/mobile application (hereinafter "site") from which it was retrieved, the "lifetime" of the file (for example, how long it will remain on the device), and a value, which is usually a randomly generated unique number.

3.1. The Operator has the right to:

• obtain truthful information and/or documents containing personal data from the data subject;
• continue processing personal data without the consent of the data subject in case of revocation of consent if there are grounds specified in the Personal Data Law;
• independently determine the set and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
• The site may also collect and process impersonal data about visitors (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics and others).
• Specifically, this includes the following data:

Java on/off;
Cookies on/off;
Abbreviated IP address (the last three digits are deleted);
URL of the referring domain (previously visited page);
Operating system;
Date and time of the visit;
Information about the interaction with the page (height of scrolling, clicks and mouse movements);
Time and duration of interactions with the page;
Subpages visited and corresponding dwell time;
Search terms entered;
Clicks on banners and links.
Additionally, each time a User accesses the Website, the servers automatically store general access data in server log files.
Such data includes the following:
The Website called;
The IP address of the requesting system;
Information about the type and version of the browser used;
The operating system used.
Use of special features of the Internet site

3.2. The Operator is obliged to:

• provide the data subject with information regarding the processing of their personal data upon request;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the necessary information to the authorized body for the protection of the rights of data subjects upon request of the body 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, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the cases and order provided by the Personal Data Law;
• perform other obligations provided by the Personal Data Law.

1. Main rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except as provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
• request from the Operator the clarification of their personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
• impose a preliminary consent condition for the processing of personal data for the purposes of promoting goods, works, and services on the market;
• withdraw their consent to the processing of personal data;
• appeal to the authorized body for the protection of personal data subjects' rights or to the court for the unlawful actions or inaction of the Operator when processing their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate data about themselves;
• inform the Operator of the clarification (updating, changing) of their personal data.

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

1. The operator may process the following personal data of the User:

5.1. Surname, name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Also, the website collects and processes depersonalized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above-mentioned data are collectively referred to as Personal data in this Policy.
5.6. The Operator does not process special categories of personal data concerning race, national origin, political views, religious or philosophical beliefs, intimate life.
5.7. The processing of personal data permitted for distribution from the special categories of personal data specified in part 1 of article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in article 10.1 of the Personal Data Law are observed.
5.8. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, in article 10.1 of the Personal Data Law, 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 process personal data permitted for distribution directly to the Operator.
5.8.2 Within three working days from the moment of receiving the User's consent, the Operator is obliged to publish information about the processing conditions, the presence of prohibitions and conditions on the processing of personal data permitted for distribution by an unlimited circle of persons.
5.8.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time at the request of the personal data subject. This request must include the surname, name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing must be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.
5.8.4 The consent to process personal data permitted for distribution ceases 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. The principles of personal data processing outlined in this document include the following:
6.1. Personal data processing should be carried out in a lawful and fair manner.
6.2. Processing of personal data should be limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the data was collected is not permitted.
6.3. It is not permitted to merge databases containing personal data that are processed for incompatible purposes.
6.4. Only personal data that is relevant to the purposes of its processing should be processed.
6.5. The content and volume of processed personal data should correspond to the stated purposes of processing. Processing of excessive personal data in relation to the stated purposes is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, when necessary, relevance to the purposes of processing should be ensured. The data controller takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data should be stored in a form that allows the subject of the personal data to be identified for no longer than required for the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary, or the surety under which is the subject of personal data. Processed personal data should be destroyed or depersonalized upon achieving the purposes of processing or when the need to achieve these purposes is lost, unless otherwise provided by federal law.

1. The purposes of personal data processing include:

7.1. Informing the User through the sending of electronic messages;
7.2. Conclusion, execution, and termination of civil contracts;
7.3. Providing the User with access to services, information, and/or materials contained on the website https://unistudy.me.
7.4. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User may always refuse to receive informational messages by sending a letter to the Operator's email address: info@unstudy.me with the subject "Refusal of notifications about new products and services and special offers."
7.5. Depersonalized data of Users collected through internet statistics services is used to collect information about User actions on the website, improve the quality of the website and its content.
8. Legal grounds for processing personal data
8.1. The legal grounds for the processing of personal data by the Operator are:

• contracts concluded between the Operator and the personal data subject;
• federal laws and other regulatory legal acts in the field of personal data protection;
• consents of Users to the processing of their personal data, for the processing of personal data authorized for dissemination.

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://unistudy.me, or sent to the Operator by email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User in case it is allowed in the User's browser settings (cookie files are enabled and JavaScript technology is used).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest.

1. Conditions for processing personal data

9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or the law, to fulfill the functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.
9.3. Processing of personal data is necessary to exercise justice, execute a court order, an act of another authority or official, which must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary to fulfill a contract, where the personal data subject is a party, beneficiary or guarantor, as well as to conclude a contract at the initiative of the personal data subject or a contract where the personal data subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out for personal data that is publicly available, the access to which is provided by the personal data subject or at their request (hereinafter - publicly available personal data).
9.7. Processing of personal data is carried out for personal data that must be published or disclosed in accordance with federal law.
10. Order of collection, storage, transmission, and other types of processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on the protection of personal data.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the performance of current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party to perform obligations under a civil contract.
10.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address: info@unstudy.me with the subject line "Updating personal data."
10.4. The processing period of personal data is determined by the achievement of the goals for which personal data was collected, unless another period is provided for by a contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at the Operator's email address: info@unstudy.me with the subject line "Revocation of consent to the processing of personal data."
In summary, paragraphs 10.5-10.9 of the Russian Federation's Federal Law No. 152-FZ on Personal Data Protection provide the following:
10.5. Any information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those operators in accordance with their User Agreement and Privacy Policy. The data subject and/or user must familiarize themselves with these documents. The operator is not responsible for the actions of third parties, including service providers mentioned in this paragraph.
10.6. The prohibitions imposed by the data subject on the transfer (except for providing access), processing or processing conditions (except for receiving access) of personal data that are allowed for dissemination do not apply in cases of processing personal data for state, public, and other public interests determined by Russian legislation.
10.7. The operator ensures the confidentiality of personal data during processing.
10.8. The operator stores personal data in a form that allows the data subject to be identified for no longer than necessary to achieve the purposes for which the personal data is processed, if the period for storing personal data is not established by federal law, a contract, or the party, beneficiary or guarantor of which is the data subject.
10.9. The processing of personal data may be terminated upon the achievement of the purposes for which the personal data was processed, expiration of the data subject's consent period, withdrawal of the data subject's consent, or identification 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, grants access), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information over information and telecommunication networks or without them.
12. Cross-border transfer of personal data:
12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is planned provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out in the presence of the written consent of the personal data subject to the cross-border transfer of their personal data and/or the performance of a contract with the personal data subject.
13.Confidentiality of personal data
The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14.Final provisions
14.1. The user can obtain any clarifications on issues related to the processing of his personal data by contacting the Operator via email: info@unstudy.me.
14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://unistudy.me.