1. General Provisions
1.1. The Policy constitutes an integral part of the User Agreement (hereinafter referred to as the Agreement) posted and/or available on the Internet at https://englex.ru/agreement-englex/, as well as other agreements entered into with the User, if expressly provided for therein.
1.2. By entering into this Agreement, you freely, voluntarily and on your own behalf give written consent to the following methods of processing your Personal Information: recording, classification, storage, adjustment (updating, alteration), retrieval, transfer (distribution, provision, accessing) to third parties, including cross-border transfer to foreign countries, anonymization, blocking, deletion, destruction for the purposes set forth in this Policy with or without the use of automation equipment at the discretion of the Owner.
1.3. The legislation of the Russian Federation shall apply to this Policy, including the interpretation of its provisions and the procedure for adoption, execution, modification and termination.
1.4. Here and hereinafter, the Policy uses the terms and definitions set forth in the Agreement, as well as in other agreements entered into with the User, unless otherwise provided in, or arises from the essence of, this Policy. Otherwise the terms used in the Policy shall be interpreted in accordance with the current legislation of the Russian Federation, business practices or scientific doctrine.
2. Personal Information
2.1. For the purposes of this Policy, Personal Information shall mean:
2.1.1. Information provided by the User during registration and authorization in, as well as during subsequent use of, the Service, including personal data of the User.
2.1.2. Information provided by the User in the course of subscribing to newsletters and to acquisition of free products from the Owner.
2.1.3. Anonymized data transmitted automatically, depending on the settings of the User's software.
2.2. The Owner has the right to establish requirements with regard to the scope of Personal Information that must be provided by the User in order to use the Service. If certain information is not indicated as mandatory by the Owner, provision or disclosure thereof shall be at the discretion of the User.
2.3. During registration, the User shall provide their first name, last name, age, city of residence, email address and phone number.
Additionally, in order to fulfill the Agreement, the User may also provide the following personal information: Skype Name, level of English, avatar or photograph, date of birth, field of work, interests.
2.4. When subscribing to receive newsletters and acquire free products from the Owner, the User shall provide their first name, email address and phone number.
2.5. The Owner does not verify that Personal Information provided by the User is accurate and that the User has obtained all necessary consents for processing thereof in accordance with this Policy, and assumes that the User acts in good faith and with due diligence, making every possible effort to keep such information up to date and to obtain all necessary consents from the subjects of such information.
2.6. The Owner automatically collects the following anonymous data:
- browser information (type, version);
- operating system information (type, version);
- request information (time, source, IP address);
- User’s location (city and country).
2.7. The User is aware of, and accepts, the possibility of third-party software being used on the Owner’s Website, as a result of which such third parties may receive and transfer the anonymous data specified in paragraph 2.1.3.
Such third-party software includes:
- maxmind.com geolocation system;
- Yandex.Metrica web analytics system;
- Google Analytics web analytics system;
- top.mail.ru web analytics system;
- Roistat end-to-end business analytics system.
The scope and terms of collection of anonymous data by such third-party software are directly determined by the owners thereof.
2.8. The Owner shall not be liable for any ways in which the User’s Personal Information may be used by third parties, with which the User interacts in the course of using the Service.
3. The Purposes of Personal Information Processing
3.1. The Owner shall only perform processing, including collection and storage, of such Personal information that is necessary for entering into, and execution of, Agreements with the Users.
3.2. The Owner has the right to use the data for the following purposes:
3.2.1. Entering into Agreements using the Service
The Agreement is entered into remotely, through exchange of electronic documents signed with a simple electronic signature. The User's email address can be used as a key for the simple electronic signature and is therefore requested during registration.
3.2.2. Identifying the User for the purposes of fulfilling obligations under the Agreements entered into with them.
The User's personal account is linked to the User's email address.
3.2.3. Fulfilling obligations under the Agreements, including provision of access to the Service and to technical support to the User, as well as the use of functionality of the Service by the User.
Requests for provision of access to the Service and support service calls are accepted via the software features of the Website (feedback form) and email.
3.2.4. Communicating with the User for the purpose of providing information services and improving the quality of the Service under the Agreements by various means, including notification via third parties.
Communication with the User is carried out via email, Skype or by subscriber phone number specified by the User during registration or in the process of using the Service.
3.2.5. Sending newsletters and free products from the Owner
Newsletters and products are sent via dashamail.ru email service. All operations involved in the processing of Personal Information of the Users are performed with the use of databases located in the territory of the Russian Federation.
4. Data Protection Requirements
4.1. The Owner shall store Personal information and protect it from unauthorized access and distribution in accordance with the legislation of the Russian Federation and internal rules and regulations.
4.2. The User's Personal Information shall remain confidential, except when the technology of the Service provided or settings of the software used by the User provide for open sharing of information with other participants and users of the Internet.
4.3. For the purposes of improving the quality of the Service, the Owner has the right to keep log files of the actions taken by the User in the process of using the Service, as well as in connection with entering into, and fulfillment of, the Agreement and other Contracts by the User, for 6 (six) months.
5.Transfer of Information
5.1. The Owner has the right to transfer the Personal Information to third parties in the following cases:
- The User has expressed their consent to such actions, including when software settings used by the User do not limit the provision of certain information.
- Transfer is required for using the functionality of the Service.
- Transfer is required for entering into and fulfilling Agreements with the use of the Service.
- At the request of a court or other authorized public authority, within the established legal procedure.
- To protect the rights and legal interests of the Owner in connection with a breach of Agreements entered into with the User.
6. Modification of Personal Information
6.1. The User has the right to:
- obtain information from the Owner relating to the processing of their Personal Information, unless such right is restricted in accordance with federal laws;
- require the Owner to modify, restrict access to or destroy their Personal Information in case it is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
- take legal actions to protect their rights.
6.2. The User has the right to withdraw their consent for processing of Personal Information in whole or in part at any time by submitting a request to this effect to the Owner. Such a request shall be sent by email to firstname.lastname@example.org or by registered mail to the address of the Owner specified in paragraph 8 of this document.
6.3. The User has the right to opt out of receiving newsletters and free products from the Owner at any time by canceling their subscription via an Unsubscribe link located at the bottom of each newsletter.
7.1. This Policy may be unilaterally amended or terminated by the Owner without prior notice to the User. The new version of the Policy comes into effect from the moment of its posting on the Owner's Website, unless otherwise specified in the new version of the Policy.
7.2. The current version of the Policy is available on the Owner's Website at https://englex.ru/privacy-englex-eng.
8. Details of the Owner
Full name: ENGLEX Limited Liability Company
Registered Office: Room 91/1, Building A, 189/6 Turgenev Street, Krasnodar, Krasnodar Krai, 350078, Russia
Current Address: Room 91/1, Building A, 189/6 Turgenev Street, Krasnodar, Krasnodar Krai, 350078, Russia
Taxpayer Identification Number (INN): 2311308881
Primary State Registration Number (OGRN): 1202300046816
Current version of the Policy dated November 11, 2020. Document designed by IT-Lex LLC.