PsyClass FZE
IBAN: AE090860000009550746105

Personal Data Processing Policy 

The use of the Website(s) and entering into relations regarding the receipt or purchase of free or paid services of the Operator means the User's unconditional consent to this Policy and the terms of processing of his personal data specified in it. In case of disagreement with these conditions, the User shall refrain from using the Website(s) and shall not enter into or continue any relationship with the Operator.

This Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in accordance with the Laws of the Russian Federation: the Constitution of the Russian Federation, the Civil Code of the Russian Federation, the Federal Law dated July 27, 2006 No. 149-FZ "On Information, Information Technologies and Information Protection", the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data" and the legal regulations of the Russian Federation adopted in accordance with them. This Policy is issued and applied by PsyClass FZE (hereinafter referred to as the Operator) in accordance with clause 2, part 1 of Art. 18.1 of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" with respect to all information that the Operator may obtain about the user during his/her use of the Operator's Websites with the following network addresses: https://psy-class.org/, https://psy-class.com/ and other addresses using the domain name psy-class.org (sections, subdomains, pages) (hereinafter referred to as the Websites) and regulates any kind of processing of personal data and personal information (any personally identifiable information and any other information related thereto) about individuals who are consumers of the Operator's products or services. This Policy covers the processing of personal data collected by any means, whether active or passive, whether through the Internet or not, from individuals located anywhere in the world.

All issues related to the processing of personal data not regulated by this Policy shall be resolved in accordance with the current legislation of the Russian Federation on personal data.

1. Personal information of Users, which is received and processed by the Websites 1.1. For the purposes of this Policy, "personal data of the user" (subject of personal data) shall mean:

1.1.1. Personal information that the User provides to Life Practice LLC about himself/herself - independently when submitting an application, making a purchase, registration (creating an account) or in any other process of using the Websites, including: name, surname, cell phone number, e-mail address, position, occupation, specialty and area of professional interests, information about education (including retraining programs and/or additional education).

1.1.2. Data that is automatically transmitted by the Websites during their use by means of software installed on the user's device, including IP address, cookie information, information about the user's browser (or other program with which the website is accessed), access time, address of the requested page, other data about visitors from visitor statistics services (address of the page where the advertising block is located, referrer (address of the previous page), etc.), geolocation data and other data, collection and processing of data on visitors, including data about the user's browser (or other program with the help of which the website is accessed).
With the help of this data, information is collected about the visitors' actions at the website in order to improve its content, improve the functionality of the website and, as a consequence, create quality content and services for visitors.
The subject of personal data may at any time change the settings of his or her browser so that all cookies are blocked or so that an alert is sent. At that the subject should be aware that in such case some features and services of the Websites may not function properly.

1.1.3. In addition to the information specified in clauses 1.1.1-1.1.2 of this Policy, the Operator shall also register data on purchases made by the subject of personal data at the Websites.

1.2. This Policy shall be applicable only to the Websites and the Operator (administrator of the Websites) does not control and is not responsible for third party sites to which the user can access through links available at the Websites. On such resources other personal information may be collected or requested from the user, as well as other actions that are not related to the Operator may be performed.

1.3. The Websites generally do not verify the accuracy of personal information provided by users and do not monitor their capacity. The operator administering the Websites assumes that the
user provides true and sufficient personal information on the matters offered in the resource forms of the Websites, and keep this information up to date.

2. Purposes of collection and processing of the Users' personal information 2.1. The Website collects and stores only those personal data which are necessary for rendering services and/or providing other values for the Users of the Website (subjects of personal data).

2.2. Personal information of the User (subject of personal data) may be used by the Operator for the following purposes:

2.2.1. Identification of the party within the framework of agreements and contracts with the Website and the Operator.

2.2.2. Providing personalized services, services and other values to the user. 2.2.3. Communication with the user, including sending notices, requests and information regarding the use of the Website, provision of services, as well as processing requests and applications from the user.

2.2.4. Improvement of the Website quality, usability, development of new services and products.

2.2.5. Targeting of informational materials.

2.2.6. Conducting statistical and other studies based on the data provided.

2.2.7. Conclusion, execution and termination of civil law contracts with individuals, legal entities, individual entrepreneurs and other persons, in cases stipulated by the current legislation. 2.2.8. Detecting, preventing, mitigating and investigating fraudulent or otherwise unlawful acts against the Operator.

3. Terms of processing of the User's personal information and its transfer to third parties 3.1. The Website generally does not verify the accuracy of personal information provided by the Users, and does not monitor their capacity. The Operator assumes that the User provides true and sufficient personal information on the issues offered in the forms of these online resources and keeps this information up to date (clause 1.3).

3.2. The User's personal information shall be kept confidential, except for cases when the User voluntarily provides information about himself/herself for public access to an unlimited number of persons.

3.3. The Website may transfer the user's personal information to third parties in the following cases:

3.3.1. The User has expressed his/her consent to such actions by providing personal data; 3.3.2. Transmission is necessary as part of the user's use of certain Websites, or to provide services, value and/or service to the user;

3.3.3. The transfer is provided for by Russian or other applicable law under a procedure established by law;

3.3.4. In order to provide an opportunity to protect the rights and legitimate interests of the Website or third parties in cases when the user violates the User Agreement of the Website. Thus, the Operator does not disclose to third parties and does not disseminate personal data without the consent of the subject of personal data, except as expressly provided for by applicable law and this Policy. In particular, the Operator transfers the User's personal data to third parties in order to provide services to the latter (for example, training at the Getcourse platform), while complying with the provisions of this Policy and taking measures to keep them safe. 3.4. When processing personal data of the Website Users, the Operator shall be guided by the Federal Law of the Russian Federation "On Personal Data".

3.5. The processing of personal data shall be organized by the Operator on the principles of: 3.5.1. Legality of the purposes and methods of personal data processing, integrity and fairness in the activities of the Operator;

3.5.2. Reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of collection of personal data that are redundant in relation to the purposes stated in the collection of personal data;

3.5.3. Processing only personal data that is relevant for the purposes for which it is processed;

3.5.4. Compliance of the content and scope of processed personal data with the stated purposes of processing. The personal data processed must not be redundant in relation to the stated purposes of their processing;

3.5.5. Inadmissibility of merging databases containing personal data processed for incompatible purposes;

3.5.6. Ensuring the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing. The Operator shall take the necessary measures or ensure that they are taken to remove or clarify incomplete or inaccurate data;

3.5.7. Storing personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing.

3.6. Processing of personal data shall be carried out by the Operator during the period necessary to fulfill the purposes for which they were collected by any lawful means, including in personal data information systems with or without the use of automation tools (mixed processing) via the Internet. In any case, the user's personal data shall be stored and processed for not longer than 15 (fifteen) years from the date of the user's consent to its processing.

3.7. All personal data shall be provided (collected) directly from the User as a subject of personal data.
The subject of personal data shall independently decide whether or not to provide his/her personal data and shall give consent to their processing by the Operator freely, of his/her own free will and in his/her own interest.

3.8. The consent specified in clause 3.7. of this Policy shall also mean the User's consent to the transfer of his/her personal data to third parties, to the assignment of processing of the said data by third parties, as well as the User's consent to the cross-border transfer of such data via the Internet (when such transfer is necessary for the effective provision of services by the Operator or is necessary for the achievement of other purposes set forth in this Policy), as well as to the receipt of e-mail and sms-newsletters within the framework of the contract of paid service provision concluded with the Operator.
In this case, cross-border data transfer means the transfer of data to third parties both in countries with an adequate level of data protection and in countries that are not such countries. The required level of personal data protection is in any case ensured by the Operator by complying with the conditions specified in Section 5 of this Policy.

3.9. Consent to the processing of personal data is provided by the User when filling out special subscription forms at the Operator's website, when applying for a free service from the Operator (registration for a webinar, etc.), signing the relevant service agreement (public offer) or directly when paying for services under the agreement (acceptance of the public offer) by checking a special "checkbox" confirming consent to the processing of personal data. In doing so, this action shall have the legal effect of written consent.

3.10. In certain cases, specifically stipulated in the Operator's local regulations, the user provides personal data in another way (different from the one specified in clause 3.9 of this Policy). For example, when filling out applications for certain types of services, submitting an application for a refund for the Operator's services - the User shall transfer personal data to the Operator by sending a letter to the e-mail address: lifepractic@gmail.com, at the same time - in case of transferring data other than those listed in clause 1.1 of this Policy - the User shall separately expresse consent to the processing of additional data.

4. Modification of personal information by the user

4.1. The User may at any time change (update, supplement) the provided personal information or its part, as well as its confidentiality parameters, by sending an application to the Operator-owner of the Websites to the e-mail address: lifepractic@gmail.com.

4.2. The User may at any time withdraw his/her consent to the processing of personal data by submitting an application to the administration at the following e-mail address: lifepractic@gmail.com.

5. Measures applied to protect the users' personal information

5.1. When processing personal data, the Operator shall apply legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data".
Ensuring the security of personal data is achieved, in particular by:

5.1.1. Assessing the effectiveness of measures to ensure the security of personal data prior to the use of such measures;

5.1.2. Detecting the facts of unauthorized access to personal data and taking measures to eliminate them and prevent their repetition;

5.1.3. Restoration of personal data modified or destroyed due to unauthorized access to it; 5.1.4. Establishing the rules of access to personal data processed in the personal data information system, as well as ensuring the registration and recording of all actions performed with personal data in the personal data information system;

5.1.5. Checking whether the contracts concluded by the Operator with third parties contain clauses on ensuring confidentiality of personal data and including them, if necessary, in the contracts;

5.1.6. Control over the measures taken to ensure the security of personal data and the level of protection of personal data information systems.

5.2. Third parties who have access to personal data on behalf of the Operator undertake to take the necessary organizational and technical measures to ensure the confidentiality of such information on their personal device from which they process personal data.

5.3. Interaction with federal executive authorities on the issues of processing and protection of personal data of the subjects whose personal data are processed by the Operator shall be carried out within the framework of the legislation of the Russian Federation.

5.4. The Operator shall be obliged to immediately stop the processing of personal data at the request of the subject of personal data as specified in part 1 of Art. 15 of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data".

6. The person responsible for the processing of personal data:

6.1. The person responsible for the processing of personal data is the Operator personally. 6.2. In its activities, the responsible person shall:

6.2.1. Exercise internal control over compliance by the Operator, its employees and contractors with the legislation of the Russian Federation on personal data to which they have access from the Operator, including requirements to personal data protection.

6.2.2. Control the reception and processing of appeals and requests of subjects of personal data.

6.2.3. Take measures to detect facts of unauthorized access to personal data and immediately take measures to protect personal data.

6.2.4. Perform constant control over ensuring the level of personal data protection. 6.2.5. Familiarize the Operator's employees, who have access to personal data, with the provisions of the Russian and EU legislation on personal data, including the requirements on personal data protection, as well as with the Operator's local regulations that determine the procedure for processing Personal Data, against signature.

6.2.6. Perform internal control and (or) audit of compliance of personal data processing with the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" and regulations adopted in accordance with it, requirements to personal data protection, this Policy and other local regulations of the Operator.

7. Responsibility of the User

7.1. Subjects of personal data shall be obliged to provide only reliable personal data to the Operator and timely notify the Operator of their changes. In this case, the Operator does not verify the reliability of personal data, and does not control the capacity of subjects of personal data, and proceeds from the fact that the subject provides reliable and sufficient personal information on the issues offered in the form of registration (subscription, payment), and keeps this information up to date.
The risk of providing inaccurate personal data shall be borne by the subject of personal data. 7.2. The Operator does not intentionally process personal data of minors. The operator recommends the use of the website to persons who are at least 18 years of age. The legal representatives of minors shall be responsible for the actions of minors, including their purchase of services at the Websites. If the Operator becomes aware that it has received personal information about a minor without the consent of legal representatives, such information will be deleted as soon as possible.

7.3. The Operator shall not be responsible for the processing of personal data of third parties, which the recipient of the Operator's services has reported as his/her own. The risk of liability in this case shall be borne by the recipient of the Operator's services who provided unreliable data.

7.4. In case the subject of personal data does not agree with the terms of this Policy in full or in part, his/her use of the Website and its services shall be immediately terminated. 8. Storage of personal data

8.1. Personal data shall be stored in electronic form in the relevant personal data information systems placed in databases in the territory of the Russian Federation.

8.2. Personal data shall be stored in a form that allows to identify the subject of personal data within the timeframe that ensures compliance with and achievement of the objectives of personal data processing established by this Policy.

8.3. Personal data shall be stored with restricted access, including by creating appropriate access levels.

8.4. Personal data contained in different electronic databases and processed for different purposes shall be stored separately.

9. Termination of processing and destruction of personal data

9.1. In case inaccurate personal data is detected upon application of a personal data subject, the Operator shall be obliged to block personal data related to this subject of personal data from the moment of such application for the period of verification, if the blocking of personal data does not violate the rights and legitimate interests of the subject of personal data or third parties.

9.2. If the fact of inaccuracy of personal data is confirmed, the Operator, based on the information submitted by the subject of personal data, shall clarify personal data within 7 (seven) business days from the date of submission of such information and remove the blocking of personal data.

9.3. In case of detection of unlawful processing of personal data by the Operator, the latter shall be obliged to stop unlawful processing of personal data within a period not exceeding 3 (three) business days from the date of such detection.If it is impossible to ensure lawfulness of personal data processing, the Operator shall destroy such personal data within a period not exceeding 10 (ten) business days from the date of detection of unlawful processing of personal data. The Operator shall notify the subject of personal data about the elimination of violations or destruction of personal data.

9.4. If the subject of personal data withdraws his/her consent to their processing, the Operator shall be obliged to stop their processing and, if the preservation of personal data is no longer required for the purposes of personal data processing, to destroy the personal data within a period not exceeding thirty business days from the date of receipt of the said withdrawal.

9.5. The Operator shall have the right to continue using personal data about the subject after consideration of withdrawal of consent to their processing, ensuring depersonalization of such information.

9.6. The Operator shall send notification of the results of consideration of the subjects of personal data requests specified in this section through the support service lifepractic@gmail.com by sending messages to the email of the personal data subject specified in the request. 10. Dispute Resolution

10.1. Before filing a claim with the court on disputes arising from the relations between the personal data subject and the Operator, it is mandatory to submit a claim (a written proposal for voluntary dispute settlement).

10.2 Within 30 (thirty) calendar days from the date of receipt of the claim, the claim recipient shall notify the claimant in writing of the results of the review of the claim.

10.3. In case of failure to reach an agreement, the dispute will be submitted for consideration to the judicial body at the place of registration of the Operator in accordance with the current legislation of the Russian Federation.

10.4. The current legislation of the Russian Federation shall apply to this Personal Data Processing Policy and relations between the subject of personal data and the Operator.

11. Miscellaneous

11.1. The Operator shall be entitled to amend this Personal Data Processing Policy without the consent of subjects of personal data.

11.2. The new version of the Personal Data Processing Policy shall come into effect from the moment it is posted at the Website, unless otherwise provided for by the new version of the Policy.

11.3. Proposals and comments for amendments to the Personal Data Processing Policy should be sent to: lifepractic@gmail.com.

11.4. Invalidity of separate regulations of this Policy, if such invalidity is recognized by the decision of a court or other authorized state body, shall not entail its invalidity as a whole. 11.5. When processing personal data, the Operator does not specifically check whether there is a special regime of personal data processing established by the legislation of the countries whose jurisdiction includes individual recipients of the Operator's services or persons who provided their data via the subscription form at the Website. If the subject of personal data is a resident of a state with a special personal data protection regime, such as the European Economic Area (EEA), and accesses the Website from European countries, the Operator shall take all reasonable steps to ensure compliance with such requirements of the personal data protection legislation established by the relevant state or group of countries (GDPR). For this purpose, the subject of personal data must notify the Operator of the existence of a special protection regime for his/her personal data by contacting the Helpdesk at lifepractic@gmail.com. 12. Details of the Operator
PsyClass FZE
IBAN : AE090860000009550746105
BIC/SWIFT : WIOBAEADXXX
Business address : Co-Working SmartDesk/408-26, Dubai, United Arab Emirates E-mail: lifepractic@gmail.com