Privacy Policy

1. Key terms

• Personal data — any information relating, directly or indirectly, to an identified or identifiable natural person (the data subject).
• Operator — the legal entity or sole proprietor that organises and/or carries out the processing of personal data.
• Processing — any action or operation performed on personal data: collection, recording, systematisation, accumulation, storage, updating, use, transfer, anonymisation, blocking, deletion, destruction.
• Data subject — a Site visitor whose personal data are processed.
• Cookie — a small file stored on the user's device that the Site uses to operate and to analyse traffic.

2. The Operator

The operator of personal data processing is:

Name (sole proprietor / company): [specify full name]

TIN (INN): [specify]

Registration number (OGRN / OGRNIP): [specify]

Address: [specify legal / actual address]

E-mail for requests: [specify e-mail]

3. What personal data are processed

The Operator may process the following personal data that the user provides voluntarily when contacting us via the Site, messengers or feedback forms:

• name (and messenger nickname);
• phone number;
• e-mail address;
• the content of the message provided voluntarily by the user.
• Anonymised data about the visit are also collected automatically via cookies and web-analytics systems: IP address, cookie data, browser and device information, referral source, on-site actions.

4. Purposes of processing

• handling enquiries and bookings for trial and regular classes;
• communicating with the user, including responding to requests;
• informing about services, schedule and events (subject to consent);
• performing a service contract to which the data subject is a party;
• improving the Site and analysing traffic and service quality (anonymised data).

5. Legal grounds for processing

The Operator processes personal data on the following legal grounds:

• the data subject's consent to the processing of their personal data;
• conclusion and performance of a contract to which the data subject is a party;
• Federal Law No. 152-FZ 'On Personal Data' and other regulations on data protection.

6. Procedure and retention periods

Personal data are processed with the data subject's consent, as well as in other cases provided for by law.

Processing is carried out by mixed means — with and without automation. The Operator does not carry out processing that results solely in automated decision-making producing legal effects.

Personal data are stored no longer than required by the purposes of processing, or until the subject withdraws consent. Once the purposes are achieved or consent is withdrawn, the data are deleted or anonymised, unless the law provides otherwise.

7. Transfer to third parties

The Operator does not sell or disclose personal data to third parties, except where necessary to achieve the purposes of processing, namely:

• messaging services (Telegram) — when the user contacts us via the relevant channel;
• the Site's hosting and infrastructure provider — for technical operation;
• web-analytics systems (e.g. Yandex.Metrica) — as anonymised data for traffic analysis;
• authorised state bodies — in the cases and manner established by law.

8. Cross-border transfer

Use of certain third-party services (in particular, messengers) may involve transferring data to foreign jurisdictions. By choosing such communication channels, the user agrees to the data-processing terms of the respective services.

9. Cookies

The Site uses cookies and similar technologies to operate, remember preferences and analyse traffic. Technical cookies are required for the Site to work correctly; analytics cookies help understand how the Site is used.

The user may restrict or disable cookies in their browser settings. Disabling some cookies may affect certain Site features. By continuing to use the Site, the user consents to the use of cookies in accordance with this Policy.

10. Rights of the data subject

The data subject has the right to:

• receive information concerning the processing of their personal data;
• request the correction, blocking or destruction of personal data that are incomplete, outdated, inaccurate or unlawfully obtained;
• withdraw consent to the processing of personal data by writing to the Operator's e-mail;
• appeal the Operator's actions or omissions to the supervisory authority (Roskomnadzor) or in court.

11. Data protection measures

The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions.

12. Changes to this Policy

The Operator may amend this Policy. The new version takes effect upon being published on the Site, unless otherwise stated. The current version is always available on this page.

13. Contact

For questions about the processing of personal data and to exercise your rights, please contact the Operator by e-mail: [specify e-mail for requests].