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Privacy Policy

1. General provisions

This Privacy Policy (the “Policy”) sets out how the personal data left by visitors on the website of the Centre for Social and Cultural Adaptation (the “Centre”) is processed and protected.

The data operator is [ЗАПОЛНИТЬ: full legal name of the organisation, OGRN, INN, registered address]. The company that developed the website is not a data operator and takes no independent decisions about the processing of personal data.

The Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and applies to all data the operator receives through the forms on this website.

The current version of the Policy is always published on this page.

2. What data is collected

When you register for a lecture or another event of the Centre — including when the data is filled in on site, if you come without registering in advance — the following is collected:

  • required: surname, first name, patronymic (if any), date of birth, citizenship, phone number;
  • optional, at your discretion: e-mail address, sex, length of stay in Russia, level of Russian, town or city of residence, the reason you are contacting the Centre.

Together with this, service information is stored: the event you registered for, the attendance mark and the time it was made, and the language the form was filled in.

When you send a message through the feedback form, the following is collected: name, e-mail address, the text of the message, the date and time the consent box was ticked, and the language of the form.

No other data is collected: the website has no user registration and no personal accounts.

3. What data is deliberately not collected

The operator does not request and does not store:

  • information about ethnicity, religion, health, political views or any other special category of personal data (Article 10 of Federal Law No. 152-FZ);
  • document details: passport, work patent, SNILS, INN, migration card or any other permit;
  • the exact residential address or the exact date of entry into the Russian Federation;
  • the IP address of the person submitting the form or information about their device.

Please do not enter such information into the free-text fields of the forms.

4. Purposes of processing

  • registering a visitor for a particular lecture or event and contacting them about that registration;
  • confirming, by the participant themselves, that they attended the event;
  • recording the services provided by the Centre and preparing the reports on them: confirmed attendance is the primary data for such reporting, and the funding of the Centre depends on it;
  • considering a message received through the feedback form and replying to it.

The data is not used for advertising or mailing lists and is not passed to anyone for such purposes.

5. Legal basis for processing

Processing is carried out on the basis of the consent of the data subject, given by ticking the relevant box in a form on the website (Article 6(1)(1) of Federal Law No. 152-FZ). The text of the consent is published on the “Consent to the processing of personal data” page.

If the data relates to a minor, the consent is given by their parent or other legal representative.

6. How data is processed and protected

Processing is mixed — both with and without the use of automation. The data is stored in the database of the website on servers located in the Russian Federation.

Access to the data is granted only to authorised employees of the Centre who need it for the purposes listed in section 4. The operator takes legal, organisational and technical measures to protect the data against unlawful access, destruction, alteration and disclosure.

Lists of registered participants and of those who marked their attendance are not published on the website and are not shown to other visitors.

7. Disclosure to third parties

Personal data is not sold, published or passed to third parties, except in two cases:

  • information about the services provided is included in the reports of the Centre submitted to [ЗАПОЛНИТЬ: name of the authority the Centre reports to] — to the extent necessary to confirm that the service was provided;
  • disclosure is required by law — at the duly formalised request of the competent state authorities.

No cross-border transfer of personal data takes place.

8. Retention periods

Data left when registering for an event is kept for 365 days from the date of registration; data from a message sent through the feedback form is kept for 365 days from the date of the message. After that the data is destroyed.

The law does not set a fixed period for such data: it requires that data be kept no longer than the purposes of processing require (Article 5 of Federal Law No. 152-FZ). The period of 365 days has been set by the operator on the basis of the annual reporting cycle for the services provided.

If the consent is withdrawn earlier, processing stops and the data is destroyed within no more than 30 days from the date the withdrawal is received (Article 21 of Federal Law No. 152-FZ), except where the law obliges the operator to keep it.

9. Rights of the data subject

A person who has left their data has the right to:

  • obtain information about the processing of their data: confirmation that it is being processed, the purposes and methods, the data processed and the retention periods;
  • demand that the data be corrected if it is incomplete, out of date or inaccurate;
  • demand that the data be blocked or destroyed if it was obtained unlawfully or is not needed for the stated purposes;
  • withdraw their consent to processing at any time;
  • appeal against the actions of the operator to Roskomnadzor (the Federal Service for Supervision of Communications, Information Technology and Mass Media) or in court.

10. How to contact the operator and withdraw consent

A request, enquiry or withdrawal of consent may be sent to the operator in free form — by phone or to the e-mail address of the Centre given at the bottom of every page of this website, or in writing to: [ЗАПОЛНИТЬ: postal address of the operator].

Please state your surname, first name, patronymic and the phone number you entered in the form — otherwise the record cannot be found. A reply is sent within 30 days of the request.

The person responsible for organising the processing of personal data: [ЗАПОЛНИТЬ: position, surname and initials, contact].

11. Cookies and web analytics

The website uses only the technical cookies needed for it to work. No information about visitor behaviour is collected for advertising purposes. If web analytics systems are connected to the website, this Policy will be supplemented before they are enabled.

12. Changes to the Policy

The operator may amend the Policy. A new version takes effect when it is published on this page. The current version was approved on [ЗАПОЛНИТЬ: date of approval].