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Individual Entrepreneur Yana Valeryevna Yakusheva
(hereinafter referred to as the “Operator”)

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1. GENERAL PROVISIONS

1.1. This Policy of Individual Entrepreneur Yana Valeryevna Yakusheva (hereinafter referred to as the “Operator”) regarding the processing of personal data (hereinafter referred to as the “Policy”) has been developed in accordance with Federal Law No. 152‑FZ “On Personal Data” dated July 27, 2006, and other applicable laws of the Russian Federation.

1.2. This Policy is intended to define the procedure for processing and measures to ensure the security of personal data of individuals that the Individual Entrepreneur Yana Valeryevna Yakusheva may obtain through the website https://thetameditation.org/ (hereinafter referred to as the “Site”) and by other means, and also defines the terms and principles of personal data processing, the rights of Users and the obligations of the Operator, as well as information about the measures implemented to protect the processed personal data.

1.3. This Policy applies to all personal data received by the Operator.

1.4. In case of disagreement with the terms of this Policy, the User must immediately cease any use of the Sites https://yanayakusheva.ru/, https://thetameditation.org/, social networks, and any other information channels of the Operator.

1.5. The Operator processes personal data only when such data are filled in and/or sent by the Data Subject independently through special forms located on the sites https://yanayakusheva.ru/, https://thetameditation.org/, or by sending a message with data to the Operator via social networks, messengers, chatbots, or by making a phone call. The transmission by the Data Subject of their personal data to the Operator constitutes unconditional consent of the Data Subject to the terms of this Policy and the conditions for personal data processing set forth herein. If the Data Subject does not agree with the terms of this Policy, they must refrain from transmitting personal data to the Operator.

1.6. Use of the Site using a web browser that accepts cookies and uses JavaScript technology means the Data Subject consents to the Operator collecting and processing such anonymized data for the purpose of improving the Site, its content, and functionality.

1.7. The Operator processes personal data by automated and non‑automated means, using computer equipment and without using such equipment.

1.8. Actions for processing personal data include collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.

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2. TERMS AND DEFINITIONS

2.1. The following terms are used in this Policy:

SITE – an internet website located at https://thetameditation.org/ and at https://yanayakusheva.ru/.

PERSONAL DATA (hereinafter – PD) – any information relating directly or indirectly to a specifically identified or identifiable natural person (Data Subject), including surname, first name, patronymic, date of birth, email address, mobile phone number, addresses of social media pages and profiles, residential address, photo and video images, user ID, and other information that allows unambiguous identification of the User.

BLOCKING OF PD – temporary suspension of PD processing (except in cases where processing is necessary to clarify PD).

ANONYMIZATION OF PD – actions that make it impossible, without the use of additional information, to determine the ownership of PD to a specific Data Subject.

PROCESSING OF PD – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of PD.

OPERATOR – Individual Entrepreneur Yana Valeryevna Yakusheva, INN: 590202740930, OGRN: 305590230400033, Email: yanayakusheva1000000000@mail.ru. The Operator independently organizes and carries out PD processing, determines the purposes of PD processing, the composition of PD to be processed, and the actions (operations) performed with PD.

PERSONAL ACCOUNT – a set of protected pages of the Site created as a result of User registration and accessible upon entering their authentication data (email address and password) into the designated fields on the Site or on the Getcourse platform and other platforms through which information and interaction between the Operator and the User take place.

PROVISION OF PD – actions aimed at disclosing PD to a specific person or a specific group of persons.

DISTRIBUTION OF PD – actions aimed at disclosing PD to an indefinite circle of persons (transfer of PD) or at familiarizing an unlimited circle of persons with personal data, including public disclosure of PD in the media, posting in information and telecommunication networks, or granting access to personal data in any other way.

USER – a visitor to the Operator’s Site, social networks, or information channels, a Data Subject.

DESTRUCTION OF PD – actions that make it impossible to restore the content of PD in the personal data information system, and/or actions that destroy the physical media of PD.

Cookies – data that are automatically transmitted to the Operator during the use of the Site using software installed on the User’s device, including IP address, geographic location, browser information and operating system type of the User’s device, technical specifications of the hardware and software used by the User, date and time of access to the Site and the Operator’s platforms. By accepting the terms of this Policy, you consent to the use of cookies.

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3. LEGAL BASES AND PURPOSES OF PERSONAL DATA PROCESSING

3.1. The legal bases for the Operator’s processing of PD are:

· The Civil Code of the Russian Federation;
· Federal Law No. 152‑FZ of July 27, 2006 “On Personal Data” (hereinafter – Federal Law No. 152);
· Federal Law of the Russian Federation No. 149‑FZ of July 27, 2006 “On Information, Information Technologies and Protection of Information”;
· Resolution of the Government of the Russian Federation No. 1119 of November 1, 2012 “On Approval of Requirements for the Protection of Personal Data during Their Processing in Personal Data Information Systems”;
· Resolution of the Government of the Russian Federation No. 687 of September 15, 2008 “On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out without the Use of Automation Tools”;
· Order of the FSTEC of Russia No. 21 of February 18, 2013 “On Approval of the Composition and Content of Organizational and Technical Measures for Ensuring the Security of Personal Data during Their Processing in Personal Data Information Systems”;
· Other applicable regulatory legal acts;
· Local legal acts of the Operator;
· The User’s consent to the processing of personal data.

3.2. The Operator processes anonymized data about the Site User if this is permitted in the User’s browser settings (cookies and JavaScript technology enabled).

3.3. The Operator processes the User’s PD exclusively for the following purposes:

3.3.1. Conclusion of contracts and performance by the Operator of obligations to the User thereunder (in particular, the User Agreement, public offers, and other agreements). Performance of obligations includes, in particular, informing about the date and time of online events (including by phone calls and sending SMS messages, messages in messengers “WhatsApp”, “Viber”, “Telegram”, “Vk.com”); sending electronic files, etc.; sending advertising, informational, and reference materials to email addresses, phone numbers, and social networks of the User;

3.3.2. Sending by the Operator to the User of advertising messages, informational newsletters about the Operator’s and its partners’ products and services, special offers, promotions, sweepstakes, contests, surveys to the User’s email address, phone number (or username) in messengers “WhatsApp”, “Viber”, “Telegram”, “Vk.com” via postal mail, SMS messages, push notifications, as well as communicating such information to the User orally by phone. The User consents to receive advertising and informational materials from the Operator to their email addresses, phone number (including SMS messages), and social networks;

3.3.3. Posting on the Site, in official groups on social networks and other Operator communities on the Internet, and other advertising and information sources, for purposes not related to identifying the User: (a) video and photo materials obtained in the process of providing services; (b) reviews left by the User about the services provided by the Operator;

3.3.4. Improving the quality of User service and modernizing the Site by processing User requests and applications, as well as for recording telephone conversations with the Operator, for improving service quality and preserving evidence in case of disputes between the Operator and the User;

3.3.5. Statistical and other research based on anonymized information provided by the User;

3.3.6. The specific scope of PD processed for the above purposes is defined in Section 5 of this Policy.

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4. TERMS AND PROCEDURE FOR PROVIDING CONSENT TO THE PROCESSING OF PERSONAL DATA BY THE OPERATOR

4.1. The Operator does not verify the PD provided by the User. In this regard, the Operator assumes that when providing PD on the Site, the User:

4.1.1. Is a legally capable person;

4.1.2. Provides accurate information about themselves to the extent necessary for using the Site. The User independently keeps the provided PD up‑to‑date. The Operator is not responsible for the User providing another person’s, inaccurate, or insufficient information;

4.1.3. Understands that information about themselves posted on the Site may become available to other Users of the Site, may be copied and distributed by such Users.

4.2. The User accepts the terms of this Policy and gives the Operator informed and conscious consent to the processing of their PD on the terms provided for in this Policy and the Law:

4.2.1. Upon registration and identification on the Site and Platforms for interaction between the User and the Operator – for PD that the User provides to the Operator: by filling out the registration form, the User is deemed to have given consent to the processing of their PD at the moment of clicking the “Register” button;

4.2.2. Upon entering or changing PD in the “Personal Information” section of the Personal Account – when editing or supplementing information in the “Personal Information” section. At the User’s option, the User may indicate the following information in the Personal Account on the Operator’s sites or platforms: date of birth; gender; image (photo uploaded through the Site or specified in a social network/electronic service); links to social media profiles. Such PD may be used to fulfill the Operator’s obligations under the User Agreement, terms of use of the Site services, and service agreements. The User is deemed to have given consent to the processing of newly entered or changed PD at the moment of completing their editing. After filling in any of the fields indicated in the “Personal Information” section, the PD are updated automatically;

4.2.3. Upon filling out the feedback form, application for use of other Site and Platform services – for PD that the User provides to the Operator when filling out the feedback form on the Internet on the Site and electronic services. The User is deemed to have given consent to the processing of their PD entered into the feedback form fields at the moment of clicking the button confirming the submission of the application (the button may be named “Send”, “Submit a request”, or similarly);

4.2.4. Upon subscribing to receive informational and news materials from the Operator – by filling out the subscription form. The User is deemed to have given consent to the processing of their PD when ticking the box “I agree to the PD processing terms”;

4.2.5. Upon any use of the Site – for PD that are automatically transmitted to the Operator during the use of the Site using software installed on the User’s device. The User is deemed to have given consent to the processing of their PD at the moment of starting to use the Site;

4.2.6. Upon subscribing to receive advertising materials from the Operator – for PD that the User provides to the Operator when filling out the feedback form on the Internet on the Site and electronic services. The User is deemed to have given consent to the processing of their PD entered into the feedback form fields, for the purpose of receiving advertising materials from the Operator and its partners, at the moment the User ticks the checkbox “I agree to the terms of the Public Offer”, and/or “I agree to the PD processing terms”, and/or “I agree to the Site Terms of Use” (or checkboxes of similar content).

4.3. By performing the actions specified in clause 4.2 of this Policy, the User grants the Operator consent to process the relevant PD, the list of which is specified in Section 5 of this Policy, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision to third parties, access with the User’s consent in accordance with Section 6), anonymization, blocking, deletion, destruction of PD, with and without the use of automation tools, in accordance with the purposes specified in Section 3 of this Policy.

4.4. The consent to PD processing provided by the User in accordance with this Policy is valid from the date of such consent and for the period necessary to achieve the purposes of PD processing, or until the User revokes such consent, unless otherwise provided by the applicable legislation of the Russian Federation. The consent to PD processing provided by the User in accordance with this Policy may be revoked at any time by the User. The User may revoke previously provided consent to PD processing by sending a corresponding request in the form of an electronic document to the email address yanayakusheva1000000000@mail.ru.

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5. PERSONAL DATA PROCESSED BY THE OPERATOR

The User provides their personal data independently by:

· Filling out a form on the Site page indicating personal data (first name, last name, phone number, email address, or others);
· Joining a community on social networks (Facebook, VKontakte, Instagram) or accepting an invitation to join a community;
· Filling out a form on the Site page embedded in a social network within a community;
· Sending a message in a social network or commenting on another message in a community;
· Connecting, adding to contacts, or launching an automatic contact service (“chat‑bot”) in a messenger (Telegram, Viber, WhatsApp, VK Messenger, and others);
· Sending a message to the Operator (including to a “chat‑bot” and to a phone number) using a Messenger;
· Sending an email to the Operator’s email addresses;
· Making a phone call to the Operator’s phone numbers;
· Sending an SMS message to the Operator’s phone numbers.

The Operator processes the following PD:

· For identification of the User on the Site or Platforms used by the Operator for providing services to the User – last name and first name, image (if indicated in the “Personal Information” section);
· For maintaining communication between the Operator and Users regarding the provision of services – last name and first name, phone number, email address, social media and messenger account data;
· For processing User applications for termination of contract and refund of remuneration – last name and first name, phone number, email address, permanent registration address, bank details;
· For improving the quality of User service and conducting statistical and other research based on anonymized information – cookies.

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6. PROCESSING OF PERSONAL DATA

6.1. The Operator processes PD based on the following principles:

· lawfulness and fair basis;
· limitation of PD processing to the achievement of specific, predetermined, and lawful purposes;
· prevention of processing PD incompatible with the purposes of PD collection;
· prevention of merging databases containing PD processed for incompatible purposes;
· processing only those PD that meet the purposes of their processing;
· compliance of the content and scope of processed PD with the stated purposes of processing;
· prevention of processing PD that is excessive in relation to the stated purposes of their processing;
· ensuring accuracy, sufficiency, and relevance of PD in relation to the purposes of PD processing;
· destruction or anonymization of PD upon achieving the purposes of their processing, or in case of loss of necessity to achieve these purposes, or upon receipt from Users of a request to destroy PD, or upon receipt of a withdrawal of consent to PD processing.

6.2. The Operator processes User PD (recording, systematization, accumulation, storage, clarification (updating, changing), retrieval) using databases located on the territory of the Russian Federation.

6.3. User PD is processed by the Operator both with and without the use of automated means.

6.4. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute PD without the consent of the Data Subject, unless otherwise provided by federal law.

6.5. Processing of User PD includes the Operator performing the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision to third parties, access), anonymization, blocking, deletion, destruction.

6.6. User PD is stored on electronic media. When processing PD for the purpose of fulfilling obligations under agreements with the User, the Operator may retrieve PD and store them on tangible media. Such PD are stored for the period established by the legislation of the Russian Federation on education and archival matters. PD storage is carried out (whichever occurs first):

· until their destruction by the Operator:
  · in case the User revokes consent to PD processing or requests destruction of PD;
  · until the expiration of the consent term (clause 4.4 of this Policy).

6.7. The Operator has the right to transfer PD in accordance with the requirements of the legislation of the Russian Federation or with the consent of the PD processing subject to third parties, namely:

6.7.1. Partners, such as owners of websites and applications, advertising networks, and other partners that provide the Operator with services related to the placement and display of advertising on websites, in programs, products, or services owned or controlled by such partners;

6.7.2. Partners engaged by the Operator to provide services to Users on the Site;

6.7.3. Partners to provide Users with special offers for concluding civil law contracts.

6.8. Transfer of personal data to third parties specified in clause 6.7 of this Policy is carried out subject to the following conditions:

· the third party processes PD using databases located on the territory of the Russian Federation;
· the third party ensures the confidentiality of PD during their processing and use; undertakes not to disclose to other persons or distribute User PD without their consent;
· the third party guarantees compliance with the following measures to ensure PD security during processing: use of information security tools; detection and recording of facts of unauthorized access to personal data and taking measures to restore PD; restriction of access to personal data; registration and recording of actions with personal data; control and evaluation of the effectiveness of applied measures to ensure PD security;
· the permitted list of PD processing methods: collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction. The third party is prohibited from transferring or distributing PD.

6.9. The Operator has the right to provide information about the Data Subject to courts, law enforcement agencies, or other state bodies in cases provided for by Russian legislation.

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7. MEASURES TAKEN BY THE OPERATOR TO PROTECT PERSONAL DATA

7.1. The Operator takes necessary and sufficient legal, organizational, and technical measures to protect information provided by Users from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties. Such actions include, in particular:

· appointment of a person responsible for PD processing;
· application of organizational and technical measures to ensure PD security during their processing in information systems;
· monitoring facts of unauthorized access to PD and taking measures to prevent such incidents in the future;
· monitoring the measures taken to ensure PD security and the level of security of PD information systems.

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8. USER RIGHTS

8.1. The User makes a decision to provide their PD and gives consent to their processing freely, of their own will, and in their own interest. The User expresses their consent to PD processing in the manner set forth in clause 4.2 of this Policy.

8.2. The User has the right to receive from the Operator information concerning the processing of their PD.

8.3. The User has the right to send the Operator their requests and demands (hereinafter – “Appeal”), including regarding the use of their PD, as well as to revoke consent to PD processing. The Appeal may be sent in the following ways:

8.3.1. From the User’s email address specified during registration on the Site, to the Operator’s email address yanayakusheva1000000000@mail.ru.

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9. UPDATING, CORRECTION, DELETION, AND DESTRUCTION OF PD

9.1. The Operator undertakes to inform the User or their representative, in accordance with Article 14 of Federal Law No. 152, about the existence of PD relating to that User, and to provide an opportunity to review such PD upon the User’s or their representative’s request, within 30 (thirty) days from the date of receipt of the User’s or their representative’s request.

9.2. The Operator undertakes to provide, free of charge, the User or their representative with the opportunity to review PD relating to that User.

9.3. Within no more than 7 (seven) business days from the date the User or their representative provides information confirming that the PD are incomplete, inaccurate, or outdated, the Operator undertakes to make the necessary changes.

9.4. Within no more than 7 (seven) business days from the date the User or their representative provides information confirming that such PD were unlawfully obtained or are not necessary for the stated purpose of processing, the Operator undertakes to destroy such PD. The Operator also undertakes to notify the User or their representative of the changes made and the measures taken, and to take reasonable steps to notify third parties to whom such User’s PD were transferred.

9.5. In case the inaccuracy of PD is confirmed, the Operator, on the basis of information provided by the User or their representative, or by the authorized body for the protection of the rights of PD subjects, or other necessary documents, undertakes to update the PD or ensure their updating (if PD processing is carried out by another person acting on behalf of the Operator) within 7 (seven) business days from the date of such information and to lift the blocking of PD.

9.6. The Operator undertakes to stop processing PD or ensure that processing is stopped by a person acting on behalf of the Operator:

· if unlawful processing of PD is discovered, carried out by the Operator or a person acting on behalf of the Operator, within no more than 3 (three) business days from the date of such discovery;
· if the User revokes consent to processing of their PD;
· if the purpose of PD processing is achieved.

9.7. The Operator undertakes to destroy the User’s PD or ensure their destruction (if PD processing is carried out by another person acting on behalf of the Operator) within no more than 30 (thirty) days from the date of achieving the purpose of PD processing.

9.8. If it is not possible to destroy PD within the specified period, the Operator shall block such PD or ensure their blocking (if PD processing is carried out by another person acting on behalf of the Operator) and shall ensure destruction of PD within no more than 6 (six) months, unless a different period is established by federal laws.

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10. AMENDMENTS TO THE POLICY

10.1. The Operator reserves the right to make changes to this Policy. The User is obliged to review the text of the Policy with each new use of the Site.

10.2. The new version of the Policy takes effect from the moment it is posted in the relevant section of the Operator’s Site. Continued use of the Site or its services after the publication of a new version of the Policy constitutes the User’s acceptance of the Policy and its terms. In case of disagreement with the terms of the Policy, the User must immediately stop using the Site and its services.

10.3. All questions regarding this Policy should be sent to the Operator’s email address yanayakusheva1000000000@mail.ru.

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11. INFORMATION ABOUT THE OPERATOR

Individual Entrepreneur Yana Valeryevna Yakusheva
INN: 590202740930
OGRN: 305590230400033
Address: Perm, Sovetskaya St., 3‑kv/office 46
Email: yanayakusheva1000000000@mail.ru