PERSONAL DATA PROCESSING POLICY
YASLI-SHKOLA LLC — English translation of the policy for https://ya-sh.ru/
1. General Provisions
1.1. This Personal Data Processing Policy (the Policy) sets out the procedure and conditions for the processing of personal data by YASLI-SHKOLA Limited Liability Company (the Controller). It has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other Russian regulations governing personal data.
1.2. The Policy applies to personal data that the Controller receives from visitors to https://ya-sh.ru/ (the Website), including through feedback forms, requests and enquiries.
1.3. The Policy is publicly available on the Website. The Controller provides unrestricted access to it.
1.4. Use of the Website alone does not constitute consent to personal data processing where the law requires separate consent. The data subject provides such consent separately in the relevant form.
2. Controller Details
Full name: YASLI-SHKOLA Limited Liability Company (Общество с ограниченной ответственностью «ЯСЛИ-ШКОЛА»).
Abbreviated name: YASLI-SHKOLA LLC (ООО «ЯСЛИ-ШКОЛА»).
Taxpayer Identification Number (INN): 9718233030.
Tax Registration Reason Code (KPP): 771801001.
Primary State Registration Number (OGRN): 1237700575837.
Registered address: premises 13N/3, building 1, 9 Montazhnaya Street, Moscow, 107497, Russia.
Telephone: +7 (495) 255-24-64.
Email for personal data enquiries: zakaz@ya-sh.ru.
Website: https://ya-sh.ru/.
3. Main Principles of Personal Data Processing
3.1. The Controller processes personal data lawfully and fairly, solely for predetermined and lawful purposes.
3.2. Only personal data relevant to the purposes of processing are processed. The content and volume of data must not be excessive in relation to those purposes.
3.3. The Controller takes steps to ensure that personal data are accurate and up to date, and deletes or corrects incomplete or inaccurate data where there are lawful grounds to do so.
3.4. Personal data are retained no longer than required by the purposes of processing or the periods prescribed by Russian law. They are then destroyed or anonymised unless the law provides otherwise.
4. Categories of Data Subjects, Purposes and Types of Personal Data
4.1. Website visitors who submit a request or enquiry.
Purpose: receiving and processing requests and enquiries; providing feedback; preparing and sending information, commercial proposals and responses requested by the user; establishing and maintaining business contacts.
Data: name (if provided), telephone number, email address, organisation/company name and position (if provided), the content of the enquiry and any other information the user voluntarily supplies in a form or enquiry.
Legal grounds: the data subject’s consent; the need to process data to conclude or perform a contract to which the data subject is a party, beneficiary or guarantor, in cases provided for by law.
Processing methods: automated and non-automated processing; receipt, collection, recording, organisation, accumulation, storage, correction (updating or amendment), retrieval, use, transfer where provided for by law or lawfully required for services used by the Controller, blocking, deletion and destruction.
Processing and retention period: until the purpose is achieved or consent is withdrawn, unless other lawful grounds justify continued processing. Documents and information subject to mandatory retention are kept for the periods prescribed by Russian law.
4.2. Website visitors in relation to technical data.
Purpose: ensuring the Website operates correctly and securely, analysing its operation and improving the user experience.
Data: IP address, browser and device information, date and time of the visit, requested page address, cookies and other technical information, where collection is enabled by the Website settings and connected services.
Legal grounds: user consent where required by law, and other grounds provided for by law.
Retention period: for as long as necessary for the relevant purpose, or in accordance with the settings of the services used and legal requirements.
5. Procedure and Conditions of Personal Data Processing
5.1. The Controller processes personal data using databases, information systems and other resources required to achieve the stated purposes.
5.2. When collecting personal data of Russian citizens, including online, the Controller complies with Russian legal requirements concerning the recording, organisation, accumulation, storage, correction (updating or amendment) and retrieval of personal data using databases located in the Russian Federation, except where expressly permitted otherwise by law.
5.3. The Controller does not disclose personal data to third parties or distribute them without the data subject’s consent, except as provided for by Russian law.
5.4. The Controller may entrust processing to parties supporting the Website, hosting, feedback forms, email, CRM, web analytics and other information services used by the Controller, where there is a lawful basis and confidentiality and security requirements are met.
5.5. If personal data are transferred across borders, the Controller complies with Russian legal requirements in force at the time of the transfer.
5.6. The Controller does not process special categories of Website visitors’ personal data (racial or ethnic origin, political views, religious or philosophical beliefs, health or intimate life), unless such processing is required by law and has a separate lawful basis.
5.7. The Controller does not make decisions producing legal consequences for a data subject or otherwise affecting their rights and legitimate interests solely on the basis of automated processing, unless provided for by law or the subject’s separate consent.
6. Cookies and Web Analytics Services
6.1. The Website may use cookies and similar technologies to operate pages, retain user preferences, obtain statistical information and analyse Website use.
6.2. Users may restrict or disable cookie storage in their browser settings. Some Website functions may then operate incorrectly.
6.3. Where third-party analytics or other services are used, technical data are processed in accordance with those services’ terms and Russian legal requirements. The Controller must keep the actual list of services and Website settings consistent with this Policy.
7. Consent to Personal Data Processing
7.1. Where consent is the basis for processing, the Controller obtains it separately from other documents and information, in a form that permits confirmation that it was received.
7.2. A data subject may withdraw consent by sending an appropriate request to zakaz@ya-sh.ru or the Controller’s postal address.
7.3. Withdrawal of consent does not always result in the immediate cessation of processing. The Controller may continue processing without consent where grounds prescribed by Russian law exist.
8. Rights of the Data Subject
8.1. Data subjects may obtain information about the processing of their personal data to the extent provided for by Russian law.
8.2. They may request correction, blocking or destruction of data that are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose.
8.3. They may withdraw consent and submit other requests to the Controller as provided for by Federal Law No. 152-FZ.
8.4. They may appeal the Controller’s actions or inaction to the authorised personal data protection authority or a court.
9. Data Subject Requests
9.1. To exercise their rights, data subjects may send a request:
— by email: zakaz@ya-sh.ru;
— by post: premises 13N/3, building 1, 9 Montazhnaya Street, Moscow, 107497, Russia.
9.2. The request must allow the applicant and the nature of the request to be identified. Where provided for by law, the Controller may request information necessary to confirm the applicant’s identity or authority.
9.3. The Controller considers requests and fulfils data subjects’ requirements within the periods prescribed by Russian law.
10. Personal Data Security Measures
10.1. The Controller takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions.
10.2. In particular, the Controller identifies persons with access to personal data, restricts access, uses information security measures appropriate to the processing, carries out internal monitoring, detects and remedies violations, and restores personal data where required by law.
11. Cessation of Processing and Destruction of Personal Data
11.1. Processing ceases when its purposes have been achieved, retention periods have expired, processing is no longer necessary, consent has been withdrawn and no other lawful grounds exist, and in other cases prescribed by law.
11.2. Personal data are destroyed in a manner that prevents recovery, within the periods and according to the procedures prescribed by Russian law and the Controller’s internal policies.
12. Final Provisions
12.1. The Controller may amend this Policy. A new version takes effect when published on the Website unless it specifies another date.
12.2. The current version of the Policy must remain freely accessible on the Website.
12.3. Matters not covered by this Policy are governed by Russian law.
1.1. This Personal Data Processing Policy (the Policy) sets out the procedure and conditions for the processing of personal data by YASLI-SHKOLA Limited Liability Company (the Controller). It has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other Russian regulations governing personal data.
1.2. The Policy applies to personal data that the Controller receives from visitors to https://ya-sh.ru/ (the Website), including through feedback forms, requests and enquiries.
1.3. The Policy is publicly available on the Website. The Controller provides unrestricted access to it.
1.4. Use of the Website alone does not constitute consent to personal data processing where the law requires separate consent. The data subject provides such consent separately in the relevant form.
2. Controller Details
Full name: YASLI-SHKOLA Limited Liability Company (Общество с ограниченной ответственностью «ЯСЛИ-ШКОЛА»).
Abbreviated name: YASLI-SHKOLA LLC (ООО «ЯСЛИ-ШКОЛА»).
Taxpayer Identification Number (INN): 9718233030.
Tax Registration Reason Code (KPP): 771801001.
Primary State Registration Number (OGRN): 1237700575837.
Registered address: premises 13N/3, building 1, 9 Montazhnaya Street, Moscow, 107497, Russia.
Telephone: +7 (495) 255-24-64.
Email for personal data enquiries: zakaz@ya-sh.ru.
Website: https://ya-sh.ru/.
3. Main Principles of Personal Data Processing
3.1. The Controller processes personal data lawfully and fairly, solely for predetermined and lawful purposes.
3.2. Only personal data relevant to the purposes of processing are processed. The content and volume of data must not be excessive in relation to those purposes.
3.3. The Controller takes steps to ensure that personal data are accurate and up to date, and deletes or corrects incomplete or inaccurate data where there are lawful grounds to do so.
3.4. Personal data are retained no longer than required by the purposes of processing or the periods prescribed by Russian law. They are then destroyed or anonymised unless the law provides otherwise.
4. Categories of Data Subjects, Purposes and Types of Personal Data
4.1. Website visitors who submit a request or enquiry.
Purpose: receiving and processing requests and enquiries; providing feedback; preparing and sending information, commercial proposals and responses requested by the user; establishing and maintaining business contacts.
Data: name (if provided), telephone number, email address, organisation/company name and position (if provided), the content of the enquiry and any other information the user voluntarily supplies in a form or enquiry.
Legal grounds: the data subject’s consent; the need to process data to conclude or perform a contract to which the data subject is a party, beneficiary or guarantor, in cases provided for by law.
Processing methods: automated and non-automated processing; receipt, collection, recording, organisation, accumulation, storage, correction (updating or amendment), retrieval, use, transfer where provided for by law or lawfully required for services used by the Controller, blocking, deletion and destruction.
Processing and retention period: until the purpose is achieved or consent is withdrawn, unless other lawful grounds justify continued processing. Documents and information subject to mandatory retention are kept for the periods prescribed by Russian law.
4.2. Website visitors in relation to technical data.
Purpose: ensuring the Website operates correctly and securely, analysing its operation and improving the user experience.
Data: IP address, browser and device information, date and time of the visit, requested page address, cookies and other technical information, where collection is enabled by the Website settings and connected services.
Legal grounds: user consent where required by law, and other grounds provided for by law.
Retention period: for as long as necessary for the relevant purpose, or in accordance with the settings of the services used and legal requirements.
5. Procedure and Conditions of Personal Data Processing
5.1. The Controller processes personal data using databases, information systems and other resources required to achieve the stated purposes.
5.2. When collecting personal data of Russian citizens, including online, the Controller complies with Russian legal requirements concerning the recording, organisation, accumulation, storage, correction (updating or amendment) and retrieval of personal data using databases located in the Russian Federation, except where expressly permitted otherwise by law.
5.3. The Controller does not disclose personal data to third parties or distribute them without the data subject’s consent, except as provided for by Russian law.
5.4. The Controller may entrust processing to parties supporting the Website, hosting, feedback forms, email, CRM, web analytics and other information services used by the Controller, where there is a lawful basis and confidentiality and security requirements are met.
5.5. If personal data are transferred across borders, the Controller complies with Russian legal requirements in force at the time of the transfer.
5.6. The Controller does not process special categories of Website visitors’ personal data (racial or ethnic origin, political views, religious or philosophical beliefs, health or intimate life), unless such processing is required by law and has a separate lawful basis.
5.7. The Controller does not make decisions producing legal consequences for a data subject or otherwise affecting their rights and legitimate interests solely on the basis of automated processing, unless provided for by law or the subject’s separate consent.
6. Cookies and Web Analytics Services
6.1. The Website may use cookies and similar technologies to operate pages, retain user preferences, obtain statistical information and analyse Website use.
6.2. Users may restrict or disable cookie storage in their browser settings. Some Website functions may then operate incorrectly.
6.3. Where third-party analytics or other services are used, technical data are processed in accordance with those services’ terms and Russian legal requirements. The Controller must keep the actual list of services and Website settings consistent with this Policy.
7. Consent to Personal Data Processing
7.1. Where consent is the basis for processing, the Controller obtains it separately from other documents and information, in a form that permits confirmation that it was received.
7.2. A data subject may withdraw consent by sending an appropriate request to zakaz@ya-sh.ru or the Controller’s postal address.
7.3. Withdrawal of consent does not always result in the immediate cessation of processing. The Controller may continue processing without consent where grounds prescribed by Russian law exist.
8. Rights of the Data Subject
8.1. Data subjects may obtain information about the processing of their personal data to the extent provided for by Russian law.
8.2. They may request correction, blocking or destruction of data that are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose.
8.3. They may withdraw consent and submit other requests to the Controller as provided for by Federal Law No. 152-FZ.
8.4. They may appeal the Controller’s actions or inaction to the authorised personal data protection authority or a court.
9. Data Subject Requests
9.1. To exercise their rights, data subjects may send a request:
— by email: zakaz@ya-sh.ru;
— by post: premises 13N/3, building 1, 9 Montazhnaya Street, Moscow, 107497, Russia.
9.2. The request must allow the applicant and the nature of the request to be identified. Where provided for by law, the Controller may request information necessary to confirm the applicant’s identity or authority.
9.3. The Controller considers requests and fulfils data subjects’ requirements within the periods prescribed by Russian law.
10. Personal Data Security Measures
10.1. The Controller takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions.
10.2. In particular, the Controller identifies persons with access to personal data, restricts access, uses information security measures appropriate to the processing, carries out internal monitoring, detects and remedies violations, and restores personal data where required by law.
11. Cessation of Processing and Destruction of Personal Data
11.1. Processing ceases when its purposes have been achieved, retention periods have expired, processing is no longer necessary, consent has been withdrawn and no other lawful grounds exist, and in other cases prescribed by law.
11.2. Personal data are destroyed in a manner that prevents recovery, within the periods and according to the procedures prescribed by Russian law and the Controller’s internal policies.
12. Final Provisions
12.1. The Controller may amend this Policy. A new version takes effect when published on the Website unless it specifies another date.
12.2. The current version of the Policy must remain freely accessible on the Website.
12.3. Matters not covered by this Policy are governed by Russian law.