Privacy policy

1.1. This Policy governs the processing and protection of the personal data (“PD”) of natural persons (“Users”) who use the arsqlippoth.ru site and the Platform hosted on it.

1.2. The personal-data controller is:

Sole proprietor (IP)

Rakhmanov Dmitry Sergeevich

ИНН

532203564337

ОГРНИП

326530000000697

КПП

0

Settlement account

40802810212010788519

Bank

Korporativny Branch, PJSC Sovcombank, Moscow

Correspondent account

30101810445250000360

БИК / BIC

044525360

Website

arsqlippoth.ru

Email

info@arsqlippoth.ru

1.3. The Policy is drawn up under Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other Russian regulations. By using the Site, the User confirms agreement with this Policy.

2.1. The controller processes the following categories of PD:

• —email address — for sign-in, action confirmation and system notifications;
• —surname and first name — provided at checkout;
• —display name and short bio — only those the User enters in their profile;
• —when paying on behalf of an organisation — the legal entity’s or sole proprietor’s details;
• —session technical data: IP address, user-agent, device identifiers and cookies — for security and abuse prevention;
• —purchase records: date, amount, status and order contents — to fulfil the order and comply with the fiscalisation law (ФЗ-54).

2.2. The controller does not process special categories of PD or biometric PD. The User’s card payment details are not stored on the controller’s side.

• —concluding and performing the paid-services agreement (granting access to Courses);
• —identifying and authenticating the User in the Personal Account;
• —processing payments and issuing fiscal receipts under ФЗ-54;
• —sending service and informational messages relating to the Services;
• —ensuring security and preventing fraud and abuse;
• —handling User requests and claims;
• —complying with the requirements of Russian law.

4.1. PD is processed on the basis of: Federal Law No. 152-FZ; the contract to which the User is a party (the public offer); the User’s consent; and to fulfil the controller’s statutory duties (including ФЗ-54 and tax law).

4.2. Consent to PD processing is given by the User on accepting the Offer and/or on registration and may be withdrawn as described in Section 8.

5.1. PD is processed both with and without automation. The recording, systematisation, accumulation, storage, updating and retrieval of the PD of Russian citizens use databases located within the Russian Federation (Art. 18(5) of 152-FZ).

5.2. The controller takes the necessary legal, organisational and technical measures to protect PD: passwords are stored as Argon2id hashes; all connections use TLS; access control and action logging are applied.

5.3. Only authorised personnel of the controller, bound by confidentiality, have access to PD.

6.1. The controller transfers PD to third parties only to the extent necessary to achieve the processing purposes and on confidentiality terms:

• —the payment provider (LLC Robokassa) — to process payments;
• —the fiscal-data operator (ОФД) — to generate and send fiscal receipts under ФЗ-54;
• —the hosting provider (Platform infrastructure located in the Russian Federation).

6.2. The controller may disclose PD to authorised state bodies on the grounds and in the manner set by Russian law. No cross-border transfer of PD is carried out.

7.1. PD is kept no longer than the processing purposes require, or for the period set by law. Data relating to contract performance and settlements is kept for the periods set by tax and accounting law.

7.2. Once the purposes are achieved or consent is withdrawn, PD is deleted or anonymised unless the law provides otherwise.

8.1. The User may:

• —obtain information about the processing of their PD and a copy of it;
• —require correction, blocking or deletion of PD that is incomplete, outdated, inaccurate or unlawfully processed;
• —withdraw consent to PD processing;
• —appeal the controller’s actions to Roskomnadzor or in court.

8.2. To exercise these rights or withdraw consent, the User sends a request to info@arsqlippoth.ru. A response is provided within no more than 10 (ten) business days. Withdrawal of consent may make it impossible to render the Services and lead to termination of Platform access.

9.1. The controller uses strictly-necessary cookies only (session, locale, CSRF defence). No third-party advertising or analytics trackers are set. See the Cookie Policy on the Site for details.

10.1. The controller may amend this Policy. A new version takes effect upon publication on the Site unless stated otherwise. For any PD-processing questions, the User may contact info@arsqlippoth.ru.