Personal data processing 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 where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that make them accessible on the Internet at https://studysbs.com/.

2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means used to process such data.

2.5. Anonymization of personal data — actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal entity, or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://studysbs.com/.

2.9. Personal data authorized by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject through consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as "personal data authorized for distribution").

2.10. User — any visitor to the website https://studysbs.com/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the media, posting it on information and telecommunications networks, or providing access to personal data in any other manner.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of personal data in a personal data information system, and/or resulting in the destruction of physical media containing personal data.

3.1. The Operator has the right to:

• obtain reliable 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 or submits a request to cease the processing of personal data, the Operator may continue processing personal data without the consent of the personal data subject where grounds specified by the Personal Data Law exist;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon request, with information concerning the processing of their personal data;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date such request is received;
• publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
• take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions involving personal data;
• cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and circumstances stipulated by the Personal Data Law;
• perform other obligations stipulated by the Personal Data Law.

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 Operator shall provide such information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• 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 purpose of processing, and to take measures provided by law to protect their rights;
• require prior consent when personal data is processed for the purpose of promoting goods, works, and services in the market;
• withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or through the courts against unlawful actions or inaction by the Operator in 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 information about themselves;
• inform the Operator of any clarification (update or modification) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without that person's consent shall be liable in accordance with the legislation of the Russian Federation.

5.1. Personal data shall be processed lawfully and fairly.

5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which the personal data was collected is not permitted.

5.3. Databases containing personal data that is processed for mutually incompatible purposes may not be combined.

5.4. Only personal data that meets the purposes of its processing shall be processed.

5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy and sufficiency of the data and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take or ensure that necessary measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than is required for the purposes of personal data processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or anonymized upon achievement of the purposes of processing or when the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

Purpose of processing

Informing the User by calling their mobile phone number or sending messages via messenger.

Personal data

Surname, first name, patronymic; telephone numbers.

Legal grounds

Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection."

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.

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

7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice or enforcement of a judicial act or an act of another authority or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Personal data made accessible to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as "publicly available personal data") may be processed.

7.7. Personal data subject to publication or mandatory disclosure under federal law may be processed.

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 applicable legislation in the field of personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Under no circumstances will the User's personal data be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies in personal data are identified, the User may update the data by sending a notification to the Operator at hello@studysbs.com, with the subject line "Personal Data Update."

8.4. The period during which personal data is processed is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by an agreement or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification by email to the Operator at hello@studysbs.com, with the subject line "Withdrawal of Consent to Personal Data Processing."

8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer (except provision of access), as well as on the processing or conditions of processing (except obtaining access) of personal data authorized for distribution, shall not apply where personal data is processed in state, public, or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data when processing it.

8.8. The Operator shall store personal data in a form that allows the personal data subject to be identified for no longer than is required for the purposes of personal data processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Personal data processing may be terminated upon achievement of the purposes of processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, a request to cease processing personal data, or identification of unlawful processing of personal data.

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the resulting information via information and telecommunications networks.

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data. Such notification shall be submitted separately from the notification of the intention to process personal data.

10.2. Before submitting the above-mentioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator via email at hello@studysbs.com.

12.2. This document will reflect any changes to the Operator's Personal Data Processing Policy. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available online at https://studysbs.com/en/privacy/.