Privacy Policy Regarding Personal Data Processing
1. General Provisions
This personal data processing policy defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by ExamClouds (hereinafter referred to as the Operator).
1.1. The Operator sets its primary goal and condition for its activities as ensuring the protection of human and civil rights and freedoms when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://www.examclouds.com.
2. Basic Concepts 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 cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://www.examclouds.com.
2.4. Information system of personal data – a set of personal data contained in databases, and ensuring their processing by information technologies and technical means.
2.5. Depersonalization of personal data – actions resulting in the inability to determine, without the use of additional information, the affiliation of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://www.examclouds.com.
2.9. Personal data allowed by the subject of personal data for dissemination – personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data allowed for dissemination).
2.10. User – any visitor to the website https://www.examclouds.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. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government body, a foreign natural or foreign legal person.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and (or) the destruction of personal data material carriers.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
– receive from the subject of personal data reliable information and/or documents containing personal data;
3.2. The Operator is obliged to:
– provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
– cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data. 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.
– demand from the operator clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and also to take measures provided by law to protect their rights;
– stipulate the condition of prior consent when processing personal data for marketing purposes of goods, works, and services;
– withdraw consent for the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court for unlawful actions or inaction of the Operator in processing their personal data;
5. The Operator may process the following User's personal data
5.1. Email address;
5.2. Also, the site collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services (Google Analytics and others).
5.3. The above data are further in the text of the Policy combined under the general concept of Personal data.
5.4. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life.
5.5. User's consent to the processing of personal data allowed for dissemination is executed separately from other consents to the processing of their personal data.
5.5.1. The User provides the Operator with consent to process personal data allowed for dissemination directly.
5.5.2. The Operator is obliged within a period not exceeding three working days from the moment of receiving the User's consent to publish information about the conditions of processing, about prohibitions and conditions for processing personal data allowed for dissemination by an unlimited number of persons.
5.5.3. The transfer (distribution, provision, access) of personal data allowed by the personal data subject for dissemination must be terminated at any time upon the personal data subject's request. This request must include the surname, name, patronymic (if any), contact information (phone number, email address, or mailing address) of the personal data subject, as well as a list of personal data whose processing should be terminated. The personal data specified in this request can only be processed by the Operator to whom it is addressed.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a legal and fair basis.
6.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than is required for the purposes of personal data processing, unless the period for storing personal data is established by federal law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending emails;
– providing the User with access to services, information, and/or materials available on the website httpsː//www.examclouds.com;
7.2. Additionally, the Operator has the right to send notifications to the User about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending a letter to the Operator at the email address tatyana.milkina@gmail.com with the note "Opt-out of notifications about new products and services and special offers."
7.3. Anonymous data of Users collected using internet statistics services are used to collect information about Users' actions on the site, improve the quality and content of the site.
8. Legal Grounds for Personal Data Processing
8.1. 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 httpsː//www.examclouds.com or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.2. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (cookie files are enabled and JavaScript technology is used).
8.3. The personal data subject independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest.
9. Conditions of Personal Data Processing
9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Personal data processing is necessary for the performance of a contract, the party to which, or the beneficiary or guarantor of which, is the personal data subject, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
9.3. Personal data processing is necessary for the realization of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.4. Personal data processing is carried out for personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
10. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
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, under any circumstances, be transferred to third parties, except in cases related to the performance of applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address tatyana.milkina@gmail.com with the note "Update of personal data".
10.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected, unless another period is provided by a contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address tatyana.milkina@gmail.com with the note "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and promptly review these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this section.
10.6. The Operator ensures the confidentiality of personal data during their processing.
10.7. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, or a party to which, the beneficiary or guarantor of which is the personal data subject.
10.8. The termination conditions for the processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the personal data subject's consent, or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Obtained Personal Data
11.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with obtaining and/or transferring the received information through 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 supposed to be made provides reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject for the cross-border transfer of their personal data and/or the performance of a contract, the party to which is 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.
14. Final Provisions
14.1. The User can obtain any explanations on issues of interest related to the processing of their personal data by contacting the Operator via email at tatyana.milkina@gmail.com.
14.2. Any changes to the policy for processing personal data by the Operator 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 httpsː//www.examclouds.com/ru/privacy/.
