PRIVACY POLICY

Moscow 2022

This Privacy Policy (hereinafter referred to as the Policy) of the Autonomous Non-Profit Organization of Continuing Professional Education “Russian Language Center of Moscow State University” (hereinafter referred to as the Organization) is developed according to Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure personal data security in the Autonomous Non-Profit Organization of Continuing Professional Education “Russian Language Centre of Moscow State University” (hereinafter – the Organization) in order to protect the rights and liberties of individuals and citizens during the processing of their personal data, including the protection of the rights to personal and family privacy.

The Policy applies to all information that the Organisation may receive about the User during the use of the Organisation's official website mgu-russian.com, programmes and products of the Organisation (hereinafter referred to as the Services).

Before using the Services, users should read the terms of this Privacy Policy.

1. Terms and definitions

1.1. The following terms are used in this Policy:

“Website Administration of mgu-russian.com (hereinafter referred to as the Website Administration)” means authorized persons for website management acting on behalf of the Organization, who organize and (or) carry out the processing of personal data, as well as determine the purposes of personal data processing, scope of personal data subject to processing, actions (operations) performed with personal data.

1.1.2. “Personal data (personal information)” means any information relating to a directly or indirectly identified or identifiable natural person (the subject of personal data):

• Personal information which the User provides about itself upon registration (account creation) or in the process of using the Services, including personal data of the User. The information required for the provision of Services is specifically marked. Other information is at the User’s sole discretion.

• Data that is automatically transmitted to the Website services in the course of their use with the software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other software through which the User accesses the services), technical specifications of hardware and software used by the User, date and time of access to the services, addresses of requested pages and other similar information.

1.1.3. “Personal data processing” means any action (operation) or combination of actions (operations) performed with or without the use of means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

1.1.4. “Privacy” means the requirement for the Organisation or other person to have access to personal data to ensure that it is not disclosed without the consent of the personal data subject or another legal basis.

1.1.5. “User of the mgu-russian.com website (hereinafter referred to as the User)” means a natural person who has accessed the Website through the Internet and is using the Organization's Website as well as using its programs and products.

1.1.6. “Cookies” means a small piece of data sent by a web server and stored on a user’s computer, which the web client or web browser sends to the web server each time it makes an HTTP request to open a page on the relevant site.

1.1.7. “IP address” means the unique network address of a node on a computer network based on the IP protocol.

1.2. The organisation shall publish or otherwise provide unlimited access to this Policy pursuant to Part 2, Article 18.1 of FZ-152.

Unlimited access to this Policy is provided by posting the document on the Organisation's official website, mgu-russian.com.

2. General provisions

2.1. The Website under the domain name mgu-russian.com (hereinafter referred to as the Website) belongs to the Autonomous Non-Profit Organization of Continuing Professional Education “Russian Language Center of Moscow State University” (INN 9729020749).

2.2. By accepting the terms of this Policy, the User acknowledges its consent to the collection and processing of certain information for the purposes set out in, and in accordance with, this Policy. Using the mgu-russian.com website constitutes unreserved consent to this Policy and the terms of processing of personal information set out therein.

2.3. In case of disagreement with the terms of this Policy, the User shall stop using the Website.

2.4. Website Administration does not verify the accuracy of the personal data provided by the User of the Organisation's website.

2.5. This Policy applies only to the Organization's Website mgu-russian.com. The Website Administration shall not control and not be responsible for the websites of third parties, to which the User may go through the links available on the Organisation's Website.

3. Purposes of the processing of Users’ personal information

3.1. The Website Administration shall process the User’s personal information for the following purposes:

3.1.1. User identification for the provision of continuing professional education services.

3.1.2. Providing the User with access to personalised resources on the Website.

3.1.3. Establishment of feedback with the User, including sending notifications, requests regarding the use of the Organisation's Website, provision of educational services, quality control of the provision of services, processing of requests and applications from the User;

3.1.4. Providing the User with the information on new services, special offers, price information, newsletters and other information on behalf of the Organisation with the User's consent;

3.1.5.Confirming the accuracy and completeness of the personal data provided by the User.

3.1.6. Creating a User Account if the User has consented to the creation of an account.

3.1.7. Providing the User with effective client and technical support when problems arise in relation to the use of the Website.

3.1.8. Targeting promotional materials;

3.1.9. Conducting statistical and other studies based on anonymised data.

4. Subject of the personal data processing policy

4.1. This Policy sets out the obligations of the Website Administration not to disclose and protect the confidentiality of personal data, which the User provides at the request of the Website Administration when using the Website.

4.2. In the course of providing services by the Organisation, the User authorises the Website Administration to receive and process the following data:

4.2.1. last name, first name, patronymic of the User

4.2.2. date and place of birth

4.2.3. sex

4.2.4. e-mail address

4.2.5. User’s contact phone number

4.2.6. country and city of residence

4.2.7. passport details

4.2.8. information on education

4.2.9. More information: photo, photo ID, marriage certificate, education document, bank card details or other electronic payment facilities, Google ID, Apple ID, social media account ID.

4.3. In the course of using the Website, the User authorises the Website Administration to receive and process the following Data:

4.3.1. User's nickname, information about the User’s use of the Website, including the geographical address of the User's Internet connection point, information about the User’s searches, the time and manner of using the Website, the addresses of the Website pages visited by the User, data and screen entries that the User clicks on while using the Website (browsing history), referrer (previous page address).

4.3.2. technical information about the devices and operating systems used when visiting the Websites, the User's IP address and information about the browser used.

5. Processing personal information with Cookie and counters

5.1. Cookies transferred by the Website to the User’s devices and the User’s devices to the Website may be used by the Website Administration to provide personalised services to the User, to target the advertisements shown to the User, for statistical and research purposes, as well as to improve the quality of services.

5.2. The User acknowledges that the hardware and software it uses to visit websites on the Internet may have the function of declining cookies (for any or all websites) and of deleting previously received cookies.

5.3. The provision of certain personalised services on the Website is only possible if the acceptance and receipt of cookies is authorised by the User.

5.4. The structure of the cookie, its content and technical specifications are determined by the Website Administration and are subject to change without prior notice to the User.

5.5. Counters placed on the Website may be used to analyse User cookies, to collect and process statistical information about the use of the Website, and to ensure the functionality of the Website as a whole or individual function.

6. Methods of processing and using personal information

6.1. The User’s personal data processing shall be carried out without limitation of time, in any lawful manner, including in personal data information system with or without the use of automation means.

6.2. Subject to applicable law, the Website Administration shall have the right to use the e-mail address and contact phone number of the User to provide the User with information about the products and services of the Organization, as well as products and services similar to those requested on the Website, except in cases where the User refuses to receive the said information.

6.3. The User shall have the right at any time to refuse using of the e-mail address and contact phone number for the purposes specified by the User in one of the following ways:

6.3.1. by following the unsubscribe instructions at the end of the e-mail received from the Organisation;

6.3.2. by sending an e-mail from the User's e-mail address to rki AT mgu-russian DOT com do not send the information.

7. Transfer of User information to third parties

7.1. The Website Administration shall not transfer Users’ personal data to third parties, except as follows:

7.1.1. with the User's consent;

7.1.2. To courier services, postal organisations, telecom carriers for the purpose of providing continuing professional education services.

7.1.3. If there is a duty to transfer the information pursuant to applicable law, government or law enforcement requirements, or for the purpose of preventing crime;

7.1.4. if the transfer is provided for under Russian or other applicable law;

7.1.5. If the processing of the User’s personal information by anonymising it results in anonymised statistical data that is transferred to a third party to carry out research, carry out work or provide services on behalf of the Organisation.

8. Measures used to protect the User’s personal information

8.1. The Website Administration takes necessary and sufficient organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties with it.

9. User rights to refuse to use personal data, to alter, supplement or clarify personal data

9.1. The User shall have the right at any time to exercise the following rights in relation to those data which may be recognised as personal data under applicable law:

9.1.1. The User shall have the right to apply to the Website Administration for a copy of their personal data held by the Website Administration or information on how they are processed;

9.1.2. The User shall have the right to apply to the Website Administration to update and correct any personal data held by the Website Administration, if it is outdated or inaccurate;

9.1.3. The User shall have the right to withdraw its consent to the personal data processing.

9.2. To exercise any of the rights listed above, the User should contact rki AT mgu-russian DOT com

10. Amendments to this Policy

10.1 The Website Administration shall have the right to amend this Policy. The date of the last update is indicated when the current version has been amended. A new version of the Policy shall become effective on the date of its publication, except as otherwise provided in the new Policy. The current version is permanently available at mgu-russian.com

10.2. The law of the Russian Federation shall apply to this Policy and the relationship between the User and the Organisation arising in connection with the application of the Organisation's Personal Data Processing Policy.