Confidential

Faithful to the principle of maintaining the confidentiality of user information

The company (hereinafter referred to as S & P ) is true to the principle of maintaining the confidentiality of its customers. The S & P Privacy Policy ( “ Privacy Policy ”) applies to all personal information that we collect or provide to us offline or over the Internet, including personal information that is collected or made available through our websites (“our Websites”). ), mobile sites, applications, widgets and other mobile interactive components (collectively, our Applications ), through our official social media pages (hereinafter our Social Media Pages ), as well as through HTML emails sent to users ( hereinafter, together with the Social Media Pages, Applications and Websites, referred to as the Sites ). By visiting the Sites, the user accepts and agrees to the procedures contained in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not use the website and do not submit any personal data.

PERSONAL INFORMATION

What personal data do we collect?

” Personal data ” means data or information components that allow the user to be identified, such as:

• name;
• Username;
• mailing address (including billing and shipping addresses);
• phone number (including home and mobile numbers);
• E-mail address;
• credit and debit card numbers;
• picture or photograph in the user’s profile;
• social media account ID;
• alias;
• shopping habits;
• preferences;
• Country of Residence;
• IP address;
• name and address of the educational institution;
• name and address of the company;
• preferences in the field of educational courses;
• preferences;
• information about browsers and devices;
• information from the server system log;
• information collected through cookies , pixel tags and other technologies;
• Application usage data;
• demographic data and other information provided by users;
• location information;
• free information.

How do we collect personal data?

We and our service organizations may collect Personal Information in a variety of ways, including the following:

• Through the Sites: for example, when a user subscribes to a newsletter or makes a purchase.
• Offline: For example, when a user contacts a helpdesk.
• From other sources: for example, public databases; joint marketing partners; social platforms; friends of users or other persons connected with them through social platforms, as well as other third parties. In particular, when a user connects their social media account to their account on the Websites, we will become aware of certain Personal Data from their social media account, which may include personal information specified in such user’s profile or profiles. his friends.
• Through the user’s browser or device: Certain information is collected by most browsers or automatically through users’ devices. We use such information for statistical purposes and to ensure the proper functioning of the Sites.
• Via server system logs: A user’s IP address is a number automatically assigned by the ISP to users’ computers or devices. The IP address is detected and automatically logged into our system server logs each time a user visits the Sites, along with information about the time of the visit and the pages the user has accessed.
• With the help of cookies :Cookies allow a web server to transmit data to a computer or device for registration and other purposes. A user who does not want to allow the collection of information using cookies can use the simple settings provided in most browsers to refuse the use of cookies . For information about the cookies we use and the purposes for which they are used, please see our Cookie Policy . Your continued use of this website indicates your acceptance of these terms and conditions and consent to our use of cookies .
• Through the use of the Applications; When users download and use the Applications, we and our service organizations may track and collect data about the use of the Applications, such as the date and time the Application on the user’s device accesses our servers, as well as what information and files are uploaded to the Application by device number specific user.
• From the user: date of birth, gender, zip code, and other information such as the user’s preferred means of communication; such information may be collected upon voluntary provision by the user.
• Physical Location: We may collect information about the physical location of users’ devices.

In some cases, we may engage third parties to process payments for purchases and/or collect donations made through the Sites. However, User Personal Data may be collected by these organizations, not by us, and will be subject to the privacy policies of such organizations and not this Privacy Policy. We have no control over, and accept no responsibility for, the use or disclosure by such third parties of our users’ Personal Data.

How do we use personal data?

We may use Personal Data for the following purposes:

• to respond to user inquiries and fulfill their requests, such as sending newsletters, answering user questions and comments;
• to send administrative information to users, such as information about the Sites and changes to our terms and policies. Users cannot opt out of receiving such communications because the information they contain may be important to their use of the Sites;
• to complete the purchase and / or donation transaction, namely to process user payments, deliver orders to them, communicate with users regarding their purchases, and provide related support;
• to provide users with updates and announcements regarding our products, promotions and programs, and to send them invitations to participate in special programs;
• to enable users to communicate with each other through the Sites in accordance with the rules of the respective Sites;
• to allow users to participate in discussions on message boards, chat rooms, user profile pages, blogs, and other services through which users can post information and materials (including our Social Media Pages);
• to carry out our activities, such as analyzing and managing our operations, market research, auditing, developing new products, improving our Sites, improving our products and services, identifying usage trends, determining the effectiveness of our advertising campaigns, adapting the practices and content of the Sites taking into account the way users work with the Sites, as well as assessing the degree of user satisfaction and providing them with support (including the elimination of problems encountered by users);
• information collected through the user’s browser or device is used for statistical purposes, as well as to ensure the proper functioning of the Sites;
• for information about the purposes of using cookies , please refer to our Cookie Policy;
• we may use data about the physical location of the user’s device to provide him with personalized services and content, based on the data received. We may also share information about the physical location of a user’s device, along with the ads they have viewed and other data we collect, with our marketing partners to enable them to provide the user with personalized content and to study the effectiveness of advertising campaigns;
• as we deem necessary or appropriate: (a) under applicable law, including law outside the user’s country of residence; (b) to comply with legal process; (c) to respond to inquiries from public and government entities, including public and government entities outside the user’s country of residence; (d) to enforce our terms and conditions; (e) to protect our business and that of our affiliates; (f) to protect the rights, privacy, security and property of us and/or our affiliates, you and others; and (g) to enable us to pursue available remedies and limit our possible damages;
• Users’ personal data will be processed by S & P , both within and outside the EU/EEA/Switzerland, primarily for the purpose of processing orders, providing users with ordered products and services (including travel insurance), and for the purpose of organization of support services and marketing activities. Because our servers are located in the United States, our sales teams are located in our field offices around the world, our head office is located in Switzerland, and the schools where students choose to study also operate in our field around the world, we may share personal information users to their corporate affiliates, claims handlers and business partners both within and outside the EU/EEA/Switzerland. We share Personal Information only with business partners who need it to process orders placed by users on the Websites, such as bookings for transportation, accommodation or training services, and our partners will only receive the information for these purposes. Users’ personal information will not be shared with business partners for their marketing purposes. Please note that the composition of claims handlers and business partners may change from time to time. S & P processes users ‘ personal data in accordance with applicable privacy and data protection laws. By using our Sites, users acknowledge and agree to such transfers. Users should be aware that many countries outside the EEA do not provide the same amount of legal protection for personal data as countries within the EEA. The transfer of data will be carried out in accordance with applicable law, and we will take all necessary measures to ensure that the third parties involved provide an adequate degree of data protection. We will impose the same requirements on any future hosting and data processing entity that we engage in connection with the operation of the Sites.

PROTECTION OF PERSONAL INFORMATION

We use reasonable organizational, technical and administrative measures to protect the Personal Data we hold. Unfortunately, data transmission via the Internet and data storage systems cannot guarantee complete data protection.

If the user has reason to believe that their interaction is no longer secure (for example, the user believes that something threatens the protection of any account with us), please immediately report this problem to us through the contact form in the “Contacts” section.

ACCESS TO PERSONAL DATA, THEIR MODIFICATION AND OPTIONS FOR THEIR USE

We provide users with many options for how we use and disclose their Personal Data for marketing purposes.

• If, at any time, a user decides to stop receiving our marketing communications, this is most easily done through the “Unsubscribe” link included in the marketing communications the user receives. In addition, you can notify us of the refusal by e-mail, by phone or by contacting us through the ” Contacts” section. In your request, please indicate your opt-out of receiving our marketing communications.
• In addition, we will not disclose a user’s Personal Data to third parties (including our subsidiaries) for their direct marketing purposes, provided we receive and process a request from the user not to disclose their Personal Data to third parties for that purpose. Such a request can be sent through the “Contact Information” section. The user must make it clear in their communication that their Personal Data will not be disclosed to our subsidiaries and/or other third parties for direct marketing purposes.

Please note that changes cannot be made immediately upon request. We will endeavor to comply with user requests as soon as reasonably practicable, but under no circumstances more than 30 days after receipt of the request. Please also be aware that if a user opts out of receiving our marketing communications, we may still send the user important administrative messages that the user will not be able to opt out of receiving.

• To modify, correct, update, conceal, delete, or otherwise restrict our use of user-provided Personal Data, please contact us via the “Contact Us” form with a clear statement of your request. Please clarify in your request what information you need to change, indicate your desire to hide your Personal Data from our database, and also let us know about your other restrictions on our use of Personal Data.

We will endeavor to comply with such request as soon as reasonably practicable. Please be aware that despite our efforts, there may be pieces of information in our databases and other documents that will not be removed or changed. In addition, please note that we may need to retain certain information for the purposes of registering and/or completing transactions initiated prior to submitting a request to change or delete data (for example, when making a purchase or entering a discount code, the user will not be able to change or delete the provided Personal Data before the purchase or benefit is completed).

THIRD PARTY SITES

This Privacy Policy does not apply to the privacy and confidentiality practices of third parties, including third parties that operate third-party websites linked from S & P websites , and we are not responsible for the privacy of users’ information on third party sites. Links to third party websites on the S & P Sites do not imply endorsement by us or our affiliates of those sites.

In addition, we may provide users with access to third party features that allow users to post content to their social media accounts. Please be aware that information provided by users through these features is governed by the third party’s applicable privacy policy, and not by this Privacy Policy. We have no control over, and assume no responsibility for, such third parties’ use or disclosure of our users’ information provided through such features.

We are also not responsible for the collection, use and disclosure policies (including data protection practices) of other organizations such as Facebook, Apple, Google, Microsoft, RIM and any other app developers, app providers, social media platform service providers, providers operating systems, wireless service providers, and device manufacturers, including Personal Information disclosed by our users to other organizations through (or in connection with) the Applications or our Social Media Pages.

DATA RETENTION PERIOD

Our users’ Personal Data is stored for as long as necessary to achieve the purposes set out in this Privacy Policy.

USE OF THE SITES BY MINORS

Users between the ages of 16 and 18 should review the terms of this Privacy Policy with their parents or guardians and understand these terms. Although we are not responsible for determining the age of our users, we may perform appropriate checks. If we learn that the information we have collected was obtained from a person under the age of 16 without the consent of their parents, we will delete such information as soon as reasonably practicable and may prevent such person from accessing the relevant website.

We offer programs for children purchased by adults. To protect the privacy of children, we require parental consent from users who wish to place an order or purchase a brochure for one of our programs for users under the age of 18.

CLOSED INFORMATION

We generally ask users not to send or disclose to us Personal Information of a non-public nature (for example, information relating to racial or ethnic origin, political, religious or other beliefs, health, disease, criminal history, trade union membership) on the Sites, through the Sites and otherwise. Under certain exceptions, such as a request related to insurance coverage, we explain to users how to provide such information in a secure manner.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be subject to change. Please note the “Last Updated Date” at the top of this page, indicating the date this Privacy Policy was last modified. Changes made to this Privacy Policy come into force when a new version of the document is posted on the Site. The use by users of the Sites after the entry into force of such changes means their acceptance of the new version of the Privacy Policy.

CONTACT INFORMATION

Please contact us with any questions, comments or concerns regarding this Privacy Policy. The user has the right to tell us:

• about your unwillingness to receive communications from us in the future;
• about your desire to find out what information we have about him, to receive a copy of your Personal Data stored by us (if such requested information is provided, an administrative fee may be charged to cover postage and pay for the work of searching and processing information);
• that he considers any of his Personal Data held by us to be inaccurate, incomplete, irrelevant or irrelevant;
• about any violation of the Privacy Policy.

For all questions and complaints in connection with this Privacy Policy, please contact us using this link. We will investigate each complaint and provide a response as soon as possible after we receive it.

 

Special category of personal data

We ask that you do not send us or disclose Special Category Personal Data (concerning race, national origin, political opinions, religious or philosophical beliefs, health status, intimate life) on the Sites or in any other way. In some cases, for example, in inquiries to an insurance company or when applying for exit visas outside the Russian Federation, we will explain to you how to do this safely.

Additions to this Policy

This Policy is a local regulatory document of the IF and is stored in paper form at the location of the IF by the employee responsible for organizing the processing of PD .

We may change this Policy. Please read the inscription ” Last Updated » (Last updated) at the top of the page to see when this Policy was last modified.

This Policy may be revised in any of the following cases:

• when changing the legislation of the Russian Federation in the field of processing and protecting PD ;
• in cases of receipt of instructions to eliminate inconsistencies affecting the scope of the Policy;
• by decision of the Company’s management;
• when changing the purposes of processing PD ;
• when changing the organizational structure, structures of information and/or telecommunication systems (or introduction of new ones);
• when using new technologies for processing PD (including transmission, storage);
• when it becomes necessary to change the process of processing PD related to the activities of the Company.

Any changes to this Policy will take effect from the moment this Policy is posted on the Site. Your use of the Sites following such changes means that you accept the changed Policy.

Contacts and rights of the subject of personal data

Persons whose PD are processed by the IF can obtain clarifications on the processing of their PD by contacting the IF personally or by sending a corresponding written request to the address of the Company’s location: 105064, Moscow, st. Zemlyanoy Val, 9

In the case of sending an official request to the IF, the text of the request must indicate:

• last name, first name, patronymic of the PD subject or his representative;
• number of the main document proving the identity of the PD subject or his representative, information on the date of issue of the specified document and the issuing authority;
• information confirming that the PD subject has relations with the IF (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information);
• signature of the PD subject (or his representative).

any questions, comments or concerns about this Policy, please contact the person responsible for processing personal data: site @ shabalinpatent . com .