General Provisions
1.1. The Praed School of Management Operator’s personal data processing policy (hereinafter referred to as the «Policy») has been developed in accordance with Federal Law No. 152-FZ «On Personal Data» of July 27, 2006 (hereinafter referred to as Law No. 152-FZ), best international practices, and the requirements of European Union legislation.
1.2. This Policy defines the personal data processing procedure and measures to ensure the security of personal data received from the Operator’s users in order to ensure compliance with the requirements of Russian and European Union legislation regarding the processing of personal data of data subjects.
1.3. The following key concepts are used in this Policy:
1) Personal data — any information relating directly or indirectly to an identified or identifiable individual (personal data subject);
2) Operator — a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or processes personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data;
3) Processing personal data — any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data;
4) Automated processing of personal data — the processing of personal data using computer technology;
5) Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons;
6) Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific number of persons; 7) Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify the personal data);
8) Destruction of personal data — actions that make it impossible to restore the contents of personal data in a personal data information system and/or that result in the destruction of tangible media containing personal data;
9) Depersonalization of personal data — actions that make it impossible to determine the attribution of personal data to a specific data subject without the use of additional information;
10) Personal data information system — the set of personal data contained in databases and the information technologies and technical means that support their processing;
11) Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government agency, a foreign individual, or a foreign legal entity.
12) Confidentiality of personal data — The Operator and other persons who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by Federal Law No. 152-FZ.
- Purposes of Personal Data Processing
2.1. Personal data is processed by Praed School of Management for the following purposes:
Ensuring compliance with the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation, and legislative acts of the European Union;
Providing (delivering) goods to organizations and individuals in accordance with requests submitted through the Praed School of Management website and monitoring the results of marketing campaigns within the framework of the Praed School of Management website;
Carrying out business communications;
For other lawful purposes.
- Legal Basis for Personal Data Processing
3.1. Praed School of Management’s personal data processing policy is determined in accordance with the laws of the European Union and the Russian Federation.
- Personal Data
4.1. It is prohibited to make decisions based solely on automated processing of personal data that generate legal consequences for the personal data subject or otherwise affect their rights and legitimate interests, except in cases stipulated by federal laws or with the written consent of the personal data subject.
4.2. Personal data subjects have the right to:
information about their personal data processed on the Praed School of Management website;
access their personal data, including the right to receive a copy of any record containing their personal data, except in cases stipulated by federal laws.