Operator policy regarding the processing of personal data

1. General Provisions

LLC "ENGLISH NANNY" TIN 7727753955 collects and processes personal data exclusively for purposes necessary for carrying out our core activities and providing related services, in accordance with the principles and rules established by Federal Law of the Russian Federation dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter – Law No. 152-FZ).

We may process data specified in your personal profile on the website (hereinafter — “Profile Data”), including your: full name, address, phone number, email address, education, and employment information. 

Main terms used in the policy:

Personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).

Personal data permitted by the subject of personal data for distribution - personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner provided by this Federal Law.

Operator - LLC "ENGLISH NANNY" TIN 7727753955, a government 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 processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

Processing of personal data - any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools. The processing of personal data includes, among other things:

- collection;

- recording;

- systematization;

- accumulation;

- storage;

- clarification (updating, modification);

- retrieval;

- use;

- transfer (distribution, provision, access);

- depersonalization;

- blocking;

- deletion;

- destruction.

Automated processing of personal data - processing of personal data using computer technology.

Distribution of personal data - actions aimed at disclosing personal data to an indefinite number of persons.

Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.

Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

Depersonalization of personal data - actions as a result of which it becomes impossible without the use of additional information to determine the ownership of personal data by a specific subject of personal data.

Personal data information system - a set of personal data contained in databases and ensuring their processing by information technologies and technical means.

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

1.3. The operator who has gained access to personal data is obliged to maintain the confidentiality of personal data - not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

1.4. The subject of personal data has the right to receive information regarding the processing of their personal data, including containing:

1) confirmation of the fact of processing personal data by the operator;

2) legal grounds and purposes of processing personal data;

3) purposes and methods used by the operator for processing personal data;

4) name and location of the operator, information about persons (except for the operator's employees) who have access to personal data or to whom personal data may be disclosed under a contract with the operator or under federal law;

5) processed personal data relating to the relevant subject of personal data, the source of their receipt, unless another procedure for providing such data is provided by federal law;

6) periods of processing personal data, including storage periods;

7) the procedure for the subject of personal data to exercise the rights provided by Federal Law;

8) information about the actual or intended cross-border transfer of data;

9) the name or surname, first name, patronymic, and address of the person processing personal data on behalf of the operator, if processing is or will be entrusted to such a person;

9.1) information about the methods by which the operator fulfills obligations established by Art. 18.1  of the Federal Law;

10) other information provided by Federal Law "On Personal Data" or other federal laws.

1.5. The subject of personal data has the right to require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.

1.6. The subject of personal data has the right to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral harm in court.

1.7. The personal data operator (LLC "ENGLISH NANNY" TIN 7727753955) has the right to:

- defend its interests in court;

- provide personal data of subjects to third parties if this is provided for by applicable law (tax, law enforcement authorities, etc.);

- refuse to provide personal data in cases provided for by law;

- use the subject's personal data without their consent in cases provided for by law.

1.8. When collecting personal data, the operator must provide the subject of personal data, upon their request, with the information provided by part 7 of Article 14 of the Federal Law "On Personal Data".

1.9. When collecting personal data, including via the information and telecommunications network "Internet", the operator must ensure the recording, systematization, accumulation, storage, updating (modification), retrieval of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except as provided by paragraphs 2, 3, 4, 8 part 1 of Article 6 of the Federal Law "On Personal Data".

2. Purposes of collecting personal data

The purpose of processing Profile Data: providing you with the opportunity to use our website and services, identifying you as a user, ensuring the operation of interactive services on the website, tracking your activity when using the services to improve the quality of the services provided. Processing is carried out based on your consent expressed during registration.

We may process your personal data provided during the use of our services (hereinafter — “Service Data”), including but not limited to: experience as a childcare specialist or family requirements from a Legal Representative/Agency, history of service usage. 

The purpose of processing Service Data: ensuring the proper operation of our website, providing you with requested services, ensuring the security of the website and services provided, backing up our databases, communicating with you on issues related to the provision of services. The source of Service Data is you. Processing is carried out based on your consent and/or for the performance of a contract.

We may process information that you provide for publication on our website or through our services (hereinafter — “Published Data”), including but not limited to: reviews, comments, resumes, video presentations.

The purpose of processing Published Data: making relevant publications in the interests of other users of the website and administering our website and services. Processing is carried out based on your consent and/or for the performance of a contract.

We may process information related to financial transactions, including purchases of goods and services made through the Agency and/or on our website (hereinafter — “Financial Transaction Data”), including: your contact details, payment card data, transaction information. 

The purpose of processing Financial Transaction Data: processing and making payments, supplying purchased goods and services, maintaining financial records, ensuring the fulfillment of contractual obligations. Processing is carried out based on your consent and/or for the performance of a contract, as well as the requirements of Russian law.

We may process information contained in correspondence that we receive from you or related to it (hereinafter — “Correspondence Data”), including: the content of the communication, metadata related to the communication. 

The purpose of processing Correspondence Data: effective communication with you, processing your requests and inquiries, maintaining records and reporting on user interactions. Our website may generate metadata based on communication carried out through feedback forms on the website. Processing is carried out based on your consent and/or in the legitimate interests of the Operator (LLC "ENGLISH NANNY" TIN 7727753955), as well as for the performance of a contract.

Information from third parties

In accordance with the requirements of Law No. 152-FZ and other regulations, we may also collect and process information about our candidates from third-party sources (third parties), such as public job exchanges, online resume databases, recommendations, personal experience, references, exclusively for the purpose of assessing a candidate’s suitability for a vacancy and verifying the accuracy of the information provided and in the context of fulfilling our obligations to clients and candidates. Data collection from third parties is carried out in compliance with Russian law.

Disclosure (transfer) of personal data to third parties

We may transfer your personal data to third parties in strictly defined cases and to the extent necessary to achieve lawful processing purposes, with your explicit consent, in the performance of a contract to which you are a party, or in other cases provided for by the legislation of the Russian Federation.

Your personal data may be disclosed to the following categories of recipients:

• Parents, Caregivers, and Agencies — to ensure the operation of the platform and the provision of staff/candidate selection services, based on your consent and/or for the performance of a contract.
  
  
  

• Service providers providing IT services and system administration (e.g., hosting providers, email service providers) — exclusively for technical support and operation of the website and services, under a personal data processing agreement under which the Operator (LLC "ENGLISH NANNY" TIN 7727753955) is responsible for the actions of such a provider.
  
  
  

• Companies positioning themselves as our Partners during registration — for informing about special offers and news based on received consent.
  
  
  

• Professional consultants (e.g., lawyers, accountants, auditors) — to provide professional services to the Operator (LLC "ENGLISH NANNY" TIN 7727753955), provided they maintain personal data confidentiality.

We require all third parties to whom your personal data is transferred to maintain confidentiality and take necessary measures to ensure the security of processed data in accordance with Russian law.

Personal data processing and storage periods

The processing of personal data is carried out by us no longer than required for the purposes of processing, unless otherwise established by federal law, contract, of which the subject of personal data is a party, beneficiary, or guarantor.

The storage periods for your personal data are determined based on the purposes of their processing:

• Profile Data: stored until the user account is deleted or consent to processing is withdrawn, unless otherwise provided by law.
  
  
  

• Service Data: stored until the purposes of processing related to the provision of services and record keeping are achieved, but not less than the periods established by Russian law for storing such information (3 years]).
  
  
  

• Published Data: stored until the publication is deleted by the data subject or upon their request, unless otherwise provided by law.
  
  
  

• Financial Transaction Data: stored for the period established by Russian law for the storage of primary accounting documents and financial reporting (5 years).
  
  
  

• Correspondence Data: stored for the period necessary to process the request and maintain internal reporting, but not more than 3 years, unless a longer period is required for the fulfillment of legal obligations.
  
  
  

• Information from third parties: stored for the period necessary to achieve the purpose of collection, but not more than 1 year], unless otherwise provided by law or contract.

The processing of personal data is terminated upon achievement of the purposes of processing, expiration of storage periods, withdrawal of consent by the subject of personal data (if there are no other legal grounds for processing), detection of unlawful processing, as well as in case of termination of the Operator (LLC "ENGLISH NANNY" TIN 7727753955).

Rights of the personal data subject

According to Law No. 152-FZ, the personal data subject has the right:

• To receive information regarding the processing of their personal data, including: confirmation of processing; legal grounds and purposes of processing; processing methods used; name and location of the Operator (LLC "ENGLISH NANNY" TIN 7727753955), information about persons (except Operator employees) who have access to personal data or to whom personal data may be disclosed under a contract with the Operator or under federal law; processed personal data and the source of their receipt; periods of processing, including storage periods; the procedure for exercising the rights of the personal data subject; information about actual or intended cross-border data transfer; name or surname, first name, patronymic, and address of the person processing on behalf of the Operator, if processing is or will be entrusted to such a person; other information provided by Law No. 152-FZ.
  
  
  

• To require the Operator (LLC "ENGLISH NANNY" TIN 7727753955) to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing.
  
  
  

• To take measures provided by law to protect their rights.
  
  
  

• To withdraw consent to the processing of personal data.

Procedure for exercising the rights of the personal data subject and withdrawal of consent

To exercise their rights, as well as to obtain information regarding the processing of their personal data, the personal data subject may send a request to the Operator (LLC "ENGLISH NANNY" TIN 7727753955).

To withdraw consent to the processing of personal data, the personal data subject sends a corresponding notification to the Operator (LLC "ENGLISH NANNY" TIN 7727753955).

Requests and notifications must be sent in writing to the Operator's email address info@englishnanny.org or the Operator's postal address 119018, Moscow, Bolshaya Yakimanka St., 40, building 1.

The request (notification of withdrawal of consent) must contain:

• The number of the main identity document of the personal data subject or their representative, information about the date of issue of the specified document and the issuing authority.
  
  
  

• Information confirming the participation of the personal data subject in relations with the Operator (LLC "ENGLISH NANNY" TIN 7727753955) (for example, contract number, date of contract, user's login on the website), or information otherwise confirming the fact of processing of personal data by the Operator.
  
  
  

• The signature of the personal data subject or their representative.
  
  
  

• The phone number or email address specified during registration.

The Operator (LLC "ENGLISH NANNY" TIN 7727753955) undertakes to review the request or notification and provide a response or stop processing and destroy the data (upon withdrawal of consent, if there are no other legal grounds for processing) within the timeframes established by the legislation of the Russian Federation (no more than 10 business days from the date of receipt of the request/notification with the possibility of extension by 5 business days; no more than 30 days upon withdrawal of consent, unless otherwise provided by law or contract).

Procedure for the destruction of personal data

Personal data is subject to destruction in cases established by Law No. 152-FZ, including:

• Achievement of the purposes of processing personal data.
  
  
  

• Expiry of the personal data storage periods established by law, contract, or the consent of the subject.
  
  
  

• Withdrawal by the personal data subject of consent to the processing of personal data, if the retention of data is no longer required for the purposes of processing and there are no other legal grounds for processing.
  
  
  

• Detection of unlawful processing of personal data, if it is impossible to ensure the legality of processing.
  
  
  

• Liquidation of the Operator (LLC "ENGLISH NANNY" TIN 7727753955).

Destruction of personal data is carried out by a commission with the preparation of the relevant act. The destruction process is carried out in a way that excludes the possibility of restoring the content of personal data on the relevant physical medium. In case of processing personal data in personal data information systems, destruction is carried out by irreversibly deleting data from servers and magnetic media, followed by overwriting free space.

Measures taken by the Operator to protect personal data

The Operator (LLC "ENGLISH NANNY" TIN 7727753955) takes the necessary and sufficient legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to them. Such measures, in particular, include:

• Appointment of a person responsible for organizing the processing of personal data.
  
  
  

• Issuance of internal acts on the processing and protection of personal data.
  
  
  

• Application of legal, organizational, and technical measures to ensure the security of personal data in accordance with Article 19 of Law No. 152-FZ.
  
  
  

• Conducting internal control and (or) audit of compliance with the processing of personal data with Law No. 152-FZ and regulations adopted in accordance with it, requirements for the protection of personal data.
  
  
  

• Assessment of the harm that may be caused to personal data subjects in case of violation of Law No. 152-FZ, and correlation of such harm and measures taken by the Operator to ensure the fulfillment of obligations.
  
  
  

• Familiarization of employees of the Operator (LLC "ENGLISH NANNY" TIN 7727753955) directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, internal acts on the processing and protection of personal data.
  
  
  

• Use of encryption systems, antivirus software, and SSL/TLS protocol.

Notification of personal data subjects and the authorized body (Roskomnadzor) in case of incidents related to personal data

In accordance with the requirements of Law No. 152-FZ, in the event of the establishment of the fact of unlawful or accidental transfer (provision, distribution, access) of personal data (incident), which resulted in the violation of the rights of personal data subjects, the Operator (LLC "ENGLISH NANNY" TIN 7727753955) undertakes to:

1. Immediately notify the authorized body for the protection of the rights of personal data subjects (Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Communications – Roskomnadzor) about the incident within 24 hours from the moment of its detection. The notification must contain information about the incident, the reasons that caused it, and the alleged harm caused to the rights of personal data subjects, as well as the measures taken to eliminate the consequences of the incident.
   
   
   

2. Within 72 hours from the moment the incident is detected, send to Roskomnadzor information about the results of the internal investigation of the incident, information about the personal data subjects affected by the incident, and a list of compromised personal data.
   
   
   

3. Take all possible measures to eliminate the consequences of the incident and minimize possible harm to personal data subjects.
   
   
   

4. Notify personal data subjects whose rights have been violated as a result of the incident about the incident, the composition and volume of compromised data, as well as the measures taken by the Operator (LLC "ENGLISH NANNY" TIN 7727753955), within the timeframes and in the manner established by Russian law, if such notification does not violate the legitimate interests of other persons and does not contradict the law.

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