Legal

Personal Data Processing Policy

1. General provisions

English translation provided for information purposes only. In the event of any discrepancy, the Russian version shall prevail.
This personal data processing policy has been drawn up in accordance with the requirements of Clause 2 of Part 1 of Article 18.1 and Article 3 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by individual entrepreneur Tambov Ivan Sergeevich (hereinafter, the Operator).

1.1. The Operator’s goal and condition for carrying out its activities is to respect human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family secrets.

1.2. This Operator’s policy on the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://chessprime.online.

1.3. Main rights and obligations of the Operator.

1.3.1. The Operator has the right:

— to receive accurate information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data, to continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— to determine independently the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

1.3.2. The Operator is obliged:

— to provide the personal data subject, at their request, with information concerning the processing of their personal data;
— to organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorised body for the protection of the rights of personal data subjects, at its request, with the necessary information within 30 days of receipt of such a request;
— to publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— to take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as from other unlawful actions in relation to personal data;
— to stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other obligations provided for by the Personal Data Law.

1.4. Main rights and obligations of personal data subjects.

1.4.1. Personal data subjects have the right:

— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to require the Operator to clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
— to make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data;
— to appeal to the authorised body for the protection of the rights of personal data subjects, or in court, against unlawful actions or omissions of the Operator in processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.

1.4.2. Personal data subjects are obliged:

— to provide the Operator with accurate information about themselves;
— to inform the Operator of any clarification (update, change) of their personal data.

1.4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.


2. Purposes of collecting personal data
 
2.1. Purposes of processing the User’s personal data:

— informing the User by sending emails;
— conclusion, performance and termination of the contract for the paid provision of services (public offer) (https://chessprime.online/offer-en);
— providing the User with access to the services, information and/or materials necessary for conducting lessons.

2.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving information messages by sending the Operator an email to support@chessprime.online marked “Opt-out of notifications about new products, services and special offers”.

2.3. Anonymised data of Users collected using web analytics services is used to collect information about Users’ actions on the website and to improve the quality of the website and its content.

3. Legal grounds for processing personal data
 
3.1. The legal grounds for the processing of personal data by the Operator are:
 
— the Constitution of the Russian Federation;
— the Civil Code of the Russian Federation;
— Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”;
— federal laws and other regulations in the field of personal data protection;
— the contract for the paid provision of services (public offer) concluded between the Operator and the personal data subject;
— Users’ consents to the processing of their personal data, including personal data permitted for dissemination.

3.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through the special forms located on the website https://chessprime.online or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.

3.3. The Operator processes anonymised data about the User if this is permitted in the User’s browser settings (saving of cookies and use of JavaScript are enabled).

3.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.
 
 
4. Scope and categories of data processed, categories of personal data subjects
 
4.1. The Operator may process the personal data of the following personal data subjects:

— customers, clients and counterparties of the Operator (individuals);
— representatives/employees of the Operator’s clients and counterparties (legal entities);
— visitors to the Operator’s website(s).

4.2. The Operator may process the following personal data of the User:

— surname, first name, patronymic;
— email addresses;
— telephone numbers;
— postal addresses.
— data from messaging services (social networks).

4.3. The website also collects and processes anonymised data about visitors (including cookies) using web analytics services (Yandex Metrica, Google Analytics and others).

4.4. The above data are hereinafter in the Policy collectively referred to as Personal Data.

4.5. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.

4.6. The processing of personal data permitted for dissemination from among 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 by Article 10.1 of the Personal Data Law are observed.

4.7. The User’s consent to the processing of personal data permitted for dissemination is executed separately from other consents to the processing of their personal data. In this case, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorised body for the protection of the rights of personal data subjects.

4.7.1 The User gives consent to the processing of personal data permitted for dissemination directly to the Operator.

4.7.2 The Operator is obliged, no later than three business days from the receipt of such consent of the User, to publish information on the processing conditions and on the existence of prohibitions and conditions on the processing by an unlimited range of persons of personal data permitted for dissemination.

4.7.3 The transfer (dissemination, provision, access) of personal data permitted by the personal data subject for dissemination must be stopped at any time at the request of the personal data subject. This request must include the surname, first name, patronymic (if any) and contact information (telephone number, email address or postal address) of the personal data subject, as well as a list of the personal data whose processing is to be stopped. The personal data specified in this request may be processed only by the Operator to whom it is sent.

4.7.4 Consent to the processing of personal data permitted for dissemination ceases to be valid from the moment the Operator receives the request specified in Clause 4.7.3 of this Policy on the processing of personal data.

5. Principles of personal data processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data processed for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of its processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, its relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymised upon achievement of the purposes of processing or if achieving these purposes is no longer necessary, unless otherwise provided by federal law.

6. Conditions for processing personal data

6.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

6.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

6.3. The processing of personal data is necessary for the administration of justice and the enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

6.4. The processing of personal data is necessary for informing about promotions and new products/services, technical support, and for the performance of a contract for the paid provision of services to which the customer is a party and under which the personal data subject is the beneficiary, as well as for the conclusion, at the initiative of the personal data subject, of a contract for the paid provision of services or a contract under which the personal data subject will be the customer.

6.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

6.6. Personal data to which access by an unlimited range of persons has been granted by the personal data subject or at their request (hereinafter, publicly available personal data) is processed.

6.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

7. Procedure for collecting, storing, transferring and otherwise processing personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organisational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

7.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.

7.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

7.3. If inaccuracies are found in the personal data, the User may update it independently by sending a notice to the Operator’s email address support@chessprime.online marked “Update of personal data”.

7.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation.

The User may withdraw their consent to the processing of personal data at any time by sending a notice by email to the Operator’s email address support@chessprime.online marked “Withdrawal of consent to the processing of personal data”.

7.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User must independently familiarise themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

7.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.

7.7. When processing personal data, the Operator ensures the confidentiality of personal data.

7.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

7.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiry of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

8. List of actions performed by the Operator with the personal data received

8.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion and destruction of personal data.

8.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the information received via information and telecommunication networks.

9. Final provisions

9.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at support@chessprime.online.

9.2. 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.

9.3. The current version of the Policy is freely available on the Internet at https://chessprime.online.
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