CONFIDENTIALITY POLICY

This Confidentiality Policy (Personal Data Processing Policy) (hereinafter referred to as the "Policy") has been prepared in accordance with paragraph 2 of part 1 of Art. 18.1 of the Federal Law of the Russian Federation "On Personal Data" N 152-FZ dated July 27, 2006 (hereinafter referred to as "152-FZ") and determines the procedure for processing personal data and measures to ensure the security of personal data taken by "Event Concierge" Limited Liability Company "(OGRN 1137746163334, TIN 7728834734, KPP 772801001, hereinafter referred to as the "Company").

This Policy applies to all personal data that we collect or receive offline or online, including personal data collected or provided through our website www.eventconcierge.ru (hereinafter referred to as the "Site"), as well as via emails, which we send to you. By visiting our Site, you accept and agree to the practices described in this Policy. If you do not agree to any of the terms of this Policy, please do not use the Site or provide any data.

The Company sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets. The Company stores personal data in a form that allows determining the subject of personal data for no longer than is required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

The Company and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

If you have any questions regarding this Confidentiality Policy, you may contact us at the following email address: info@eventconcierge.ru.

Personal Data

Personal data is any information relating directly or indirectly to a specific or identifiable natural person (a subject of personal data), including, but not limited to:

  • Full Name;

  • Year, month, date and place of birth;

  • Sex;

  • Phone number/-s;

  • Passport data;

  • Information about the place of residence;

  • Information about the place of study;

  • Email address/-es.

We may receive your personal data in a variety of ways, including:

  • Via the Site: We may collect personal data through the Site, for example, when you provide information about yourself to receive feedback, create a personal account, register for competitions, subscribe to a newsletter, book a course, or take other actions on the Site (depending on the functionality implemented on the Site).

  • From you: we may collect personal data from you offline, for example when you contact us to enter into a service contract.

  • From our other sources: We may receive your personal information from other sources such as public databases; joint marketing partners; social media platforms; from people who are friends with you or with whom you are in any other way connected through social media, as well as from third parties.

By filling out any forms on the Site or submitting or providing your personal data to the Company, you express your consent to this Policy.

What Additional Information Do We Collect?

In addition to your Personal Data, we may obtain additional information through the following means:

  • Through your browser or device. Certain information is collected by most browsers or automatically through your device. We use this information for statistical purposes and to make sure the Site is working properly.

  • Through server log files. Your "IP address" is a number that is automatically assigned to your computer or device that you use to access the Internet through your ISP. The IP address is identified and recorded automatically in our server log files whenever you visit the Site, as well as the time of the visit and the pages visited.

  • When using cookies. Cookies allow a web server to transfer data to a computer or device for logging and other purposes. To learn more about cookies, please visit http://www.allaboutcookies.org/.

  • Physical location. We may receive information about the physical location of your device.

Use of Personal Data

We may use personal data for the following purposes:

  • For the conclusion, execution or termination of a civil law contract of which you are a party, beneficiary or guarantor.

  • To respond to your inquiries and fulfill your requests, for example, to contact you about your request, to send you newsletters, or to respond to your questions and comments.

  • To send you administrative information, such as information regarding the Site and changes to our terms and conditions.

  • To provide you with updates and news regarding our seminars and events, and send you invitations to participate in special programs.

  • In order to organize and conduct various competitions and events of the Company.

We can process your personal data in the following ways: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), including cross-border, blocking, deletion, destruction of personal data.

Personal data is processed until we achieve the purposes of processing or you submit a request to delete your data.

Transfer of Personal Data

In order to organize and conduct language seminars, language competitions, assist in obtaining visas, we may entrust the processing of your personal data to third parties, including those located outside the Russian Federation (cross-border transfer).

Cross-border transfer of personal data is carried out in cases:

  • your consent to a cross-border transfer;

  • performance of a contract to which you are a party;

  • protection of your life, health and other vital interests if it is impossible to obtain consent in writing;

  • if the receiving party is located in a foreign country that provides adequate protection of the rights of personal data subjects.

Cross-border transfers of data will be in accordance with applicable law and we will take all reasonable steps to ensure that the third parties involved provide an adequate level of protection.

In order to analyze consumer preferences, we may transfer your personal data to the owners of information services for analyzing user behavior on Internet sites, such as Yandex.Metrika, Google Analytics, as well as analytical agencies.

In accordance with paragraphs. 3, 3.1, 4 Article 6 of the Federal Law "On Personal Data" No. 152-FZ dated July 27, 2006 (as amended and supplemented), we may transfer your personal information to state and law enforcement agencies, new owners of the company, in the event of any legal proceedings or the possibility of litigation, and to establish, exercise and protect our legal rights (including providing information to third parties in order to prevent the possibility of fraud or reduce financial risks in accordance with the law).

Such transfer will be carried out in accordance with the requirements of the laws of the Russian Federation, subject to your legal rights and interests and the protection of personal data.

Third Party Sites

In this Policy, we do not address and are not responsible for the privacy, information or other aspects of the activities of any third parties, including any third party operating any site linked to the Site. The existence of a link on the Site does not imply endorsement by us or our affiliates of the linked site.

Use of Websites by Minors

If you are under the age of 18, you should review the terms of this Policy with your legal representative (parent or guardian) to ensure that you both understand it. While it is not our responsibility to determine the age of our users, we may perform verification checks. If we become aware that we have collected information from a person under the age of 18 without parental consent, we will delete such information as soon as possible.

To protect the privacy of minors, we require parental consent from users who are under the age of 18 when booking (purchasing) any of our services on the Site.

Special Category of Personal Data

We ask you not to send us or disclose special category personal data (racial, national origin, political opinions, religious or philosophical beliefs, health status, intimate life) to us on the Site or in any other way. In some cases, for example, in inquiries to an insurance company or when applying for exit visas outside the Russian Federation, we will explain to you how to do it safely.

Amendment of Policy

This Policy may be revised in any of the following cases:

  • when changing the legislation of the Russian Federation in the field of processing and protection of personal data;

  • in cases of receipt of orders to eliminate inconsistencies affecting the scope of the Policy;

  • by decision of the Company's management;

  • when changing the purposes of processing personal data;

  • when changing the organizational structure, the structure of information and/or telecommunication systems (or introducing new ones);

  • when applying new technologies for processing personal data (including transmission, storage);

  • if there is a need to change the process of processing personal data related to the activities of the Company.

Any changes to this Policy will take effect from the moment this Policy is posted on the Site. Your use of the Site after such changes means that you accept the changed Policy.

Contacts and Rights of the Subject of Personal Data

In accordance with applicable Russian law, you have the right to access your personal data that we store, as well as the right to clarify, block or delete your personal data or prohibit (upon request and free of charge) the processing of your personal data.

The term for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or applicable law.

The user may at any time withdraw his consent to the processing of personal data by sending the Company a notification by e-mail to the Company's email address info@eventconcierge.ru with the note "Withdrawal of consent to the processing of personal data".

Persons whose personal data are processed by the Company may receive clarifications on the processing of your personal data by contacting the Company personally or by sending a corresponding written request to the address of the Company's location: 115114 Moscow, Derbenevskaya Embankment, 1/2, Apt. 140.

The Policy is valid indefinitely until it is replaced by a new version. The current version of the Policy in the public domain is located on the Internet at www.eventconcierge.ru

Effective date: June 14, 2022.