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Personal data processing policy

We are committed to respecting the privacy of your personal data and invite you to read our privacy policy. This will tell you what data we process about you, the purposes for which we process it and how you can change, delete or otherwise influence the processing of your personal data.


1. Information on the data controller

Individual entrepreneur Oksana Nikolaevna Selendeeva

● Certificate of state registration No. 319774600370226 dated 20.06.2019

● Taxpayer identification number (INN) 212901700606

● Address: Russia, 105064, Moscow, Nizhniy Susalny lane, bld. 5, str. 19

● E-mail address: info@coddyschool.com

The Policy is rigorously enforced by Oksana Nikolaevna Selendeeva and all employees of the individual entrepreneur Oksana Nikolaevna Selendeeva.

The scope of the Policy covers the processing of personal data collected in any way, both actively and passively, via the Internet or without its use, from individuals anywhere in the world. 

The policy applies to all personal data processed by the controller, both with and without the use of automation tools.

This policy is accessible to all persons who process personal data.

The above-mentioned controller processes your personal data and is hereinafter referred to as "CODDY", "We".

2. Definitions

  1. Personal data - any information relating to a directly or indirectly identified or identifiable natural person (citizen). This information may include: full name, date and place of birth, address, information on family, social and property status, information on education, profession, income, health status and other information.

  1. Processing of personal data - any action (operation) or set of actions (operations) performed on personal data, with or without the use of automation tools. These actions (operations) may include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.


3. Data processing

Oksana Nikolaevna Selendeeva, Individual entrepreneur, processes the personal data of the following persons:

● Customers who are in a contractual relationship with the Operator;

● Employees of Oksana Nikolaevna Selendeeva, Individual entrepreneur;

● Candidates for open positions at Oksana Nikolaevna Selendeeva, Individual entrepreneur;

● Representatives of legal entities.


What data we may process:

  • Last name, first name, patronymic;

  • E-mail address;

  • Telephone number;

  • Registration address;

  • Date of birth;

  • All data provided in accounts of external services (if registration and/or authorization on the website is done via a social network or other electronic service);

  • Payment information;

  • Identity document and its details;

  • Proof of education and its details;

  • Document confirming a change of name, surname and its details;

  • Document confirming the right to dispose of maternal (family) capital (if you pay with maternal capital) and its details;

  • Social media account details;

  • Messenger account (Telegram, WhatsApp, etc.);

  • Country and city;

  • Photo/image;

  • Any other information you provide on the Website in the "About yourself" section or with similar content;

  • Information about the contract concluded between you and CODDY;

  • Cookie files;


Cookies used on the website

For all users of the website, we use cookies - these are text files containing small amounts of information that are downloaded to your computer, cell phone or other device when you visit a website. The cookies are then sent back to the original website on each subsequent visit or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device.

By using the website, you agree that we can place these types of cookies on your device.


Diagnostic and analytical cookies

These cookies collect anonymous information about the pages visited. By using the website, you agree that we can place these types of cookies on your device.

These cookies collect information about how visitors use the website, such as which pages they visit most often and whether they receive error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to improve the way the website works.


Functional cookies

These cookies allow the website to remember choices you make (such as your username, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have requested, such as displaying a photo gallery or sending a request via a feedback form. The information collected by these cookies is anonymized and they cannot track your browsing activity on other websites.


Third party cookies

These cookies allow third parties to track the success of their applications or to customize the app for you. Due to the way cookies work, neither we nor third parties can access the data in the cookies used on our website.

For example, if you choose to "share" content via X (Twitter) or other social networks, you may receive cookies from these websites. We have no control over the setting of these cookies. Therefore, please refer to these websites for information about their cookies and how you can manage them.


Cookie Opt-Out

You have the option of rejecting the use of cookies. You must make the necessary adjustments in the settings of your Internet browser to block the use of cookies on your device. You can find instructions on how to do this in the help section of your browser.

Rejecting cookies will result in the loss of functions and settings on the websites you visit.


4. Your agreement with these conditions

By using this website, you agree to these terms and conditions and give CODDY permission to process your personal data if you:

  • When you fill in feedback forms, including applications for training and requests to use other services of the website, consent to the processing of personal data is deemed to be given at the moment you click on the button confirming the submission of the form (the buttons may be labeled "Submit", "Send application" or similar) and check the box indicating acknowledgement and consent to the processing of personal data.

By participating in CODDY's marketing activities (promotions, competitions, special projects), you grant CODDY the right to send you newsletters with information material required for participation in the respective marketing activity. Your consent shall be deemed to have been given from the time of your participation in such an activity. The time from which you are deemed to be a participant in the marketing activity is determined by the rules of the respective promotion, competition or special project.

You can enter or change information in the "Personal data" section of your personal account on the website. You determine the scope of the personal data displayed in the "Personal Information" section. You can enter the following information: Last name, first name, patronymic; photo/picture; gender; date of birth; e-mail; phone number; social media account; Skype login; work/study location; position; contact person.


By agreeing to the terms of the Policy, you give CODDY your informed and conscious consent to the processing of your personal data in accordance with the terms of the Policy and the Federal Law of July 27, 2006 N 152-FL "On Personal Data" (hereinafter referred to as the Law). In doing so, we assume the following:
  • You have provided completely correct information. CODDY does not verify its authenticity. All risks associated with providing incorrect or insufficient information are your responsibility;

  • You have reached the age of 14 and are entitled to give the relevant consent in accordance with the legislation of the Russian Federation. If for any reason you do not have such a right, we assume that consent to the processing of personal data has been given by your legal representative;

  • The processing of personal data of minors who have not reached the age of 14 is carried out with the consent of the legal representative of the person concerned.


In certain cases defined by law, CODDY is authorized to process your personal data without your consent. All these cases are listed in Article 6 of the Act.


You give separate consent to the processing of your personal data for the purpose of displaying your profile to other registered users of the Website and its services in the personal account on the Website.


If you do not agree with this policy, please do not use our website. Your continued use of the Website following the posting of changes to this Policy will be deemed your acceptance of those changes.


5. How we use the information we collect


In order for you to use the website and for us to provide you with services, it is imperative that we collect and use your personal information for the following purposes:

To improve customer service: the information you provide allows us to respond more efficiently to your customer service requests and support needs.

To personalize the user experience: we may use the information collectively to understand how our users as a group use the services and resources offered on our website.

In order to improve our website, we may use the feedback you give us to improve our products and services.

For the processing of payments: we may use the information provided by users when placing an order for the sole purpose of providing services related to that order. We do not share this information with third parties unless it is necessary for the provision of the service.

To initiate a promotion, contest, survey or other website feature: to send information to users that they have consented to on topics we believe will be of interest to them.


For sending regular electronic mail: we may use this email address to send information about users and updates relating to their order. It may also be used to respond to their inquiries, questions and/or other requests. If the user subscribes to our mailing list, they will receive emails with company news, updates, relevant product or service information, etc. Should the user wish to unsubscribe from receiving future emails at any time, detailed unsubscribe instructions are provided at the bottom of each email.


6. Processing of personal data and security

The Individual entrepreneur Oksana Nikolaevna Selendeeva understands the security of personal data to mean the protection of personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data and against other unlawful actions in relation to personal data and takes the necessary legal, organizational and technical measures to protect personal data.

The processing and security of personal data by the individual entrepreneur Oksana Nikolaevna Selendeeva is carried out in strict compliance with the Constitution of the Russian Federation, Federal Law No. 152-FL "On Personal Data", additional laws and other federal laws that determine the conditions and specifics of personal data processing. This compliance also extends to the guidelines and methodological documents issued by the Federal Service for Technical and Export Control (FSTEC) of Russia and the Federal Security Service (FSS) of Russia to ensure the highest standards of privacy and data protection.

When processing personal data, Oksana Nikolaevna Selendeeva adheres to the following principles:

  • Lawfulness and fairness;

  • Limitation of the processing of personal data to the achievement of specific, predetermined and legitimate purposes;

  • Avoiding the processing of personal data in a way that is incompatible with the purposes for which it was collected;

  • Preventing the merging of databases with personal data processed for incompatible purposes;

  • Ensuring that the personal data processed is relevant and adequate for the purposes for which it is processed;

  • Ensuring the accuracy and relevance of the content.


The operator only processes personal data if at least one of the following conditions is met:

  • The processing of personal data takes place with the consent of the person whose personal data is being processed.

  • The processing of personal data is necessary for the achievement of the objectives prescribed by law, as well as for the performance of the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

  • The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor. It is also necessary for the conclusion of contracts initiated by the data subject or contracts to which the data subject is a beneficiary or guarantor.

  • The processing of personal data is necessary to safeguard the rights and legitimate interests of the company or third parties or to achieve objectives of public importance, provided that this does not infringe the rights and freedoms of the data subject.

  • Personal data is processed to which an unlimited number of persons have access, either by the data subject themselves or at their request.

  • The processing of personal data that must be published or mandatorily disclosed in accordance with federal law is carried out.

Oksana Nikolaevna Selendeeva, as an individual entrepreneur, is authorized to delegate the processing of personal data to third parties under a contract. Companies that process personal data on behalf of Oksana Nikolaevna Selendeeva are obliged to comply with the principles and rules of processing and protection of personal data, as set forth in Federal Law No. 152-FL "On Personal Data". For each company, a set of actions (operations) with personal data, the objectives of processing, the obligation to maintain confidentiality and ensure the security of personal data during processing are defined. In addition, requirements for the protection of processed personal data are defined.

In accordance with the provisions of the legislation of the Russian Federation, Oksana Nikolaevna Selendeieva, an individual entrepreneur, is authorized to transfer personal data of citizens if necessary. Public databases with personal data of employees may be created for information purposes. With the employee's consent, the public databases may contain surname, first name, patronymic, date and place of birth, position, contact telephone numbers and email addresses. An employee's information may be removed from the public databases of personal data at any time at the employee's request or by order of a court or other authorized government agency.

We destroy or anonymize personal data as soon as the purposes of the processing have been achieved or when the continuation of the processing is no longer necessary.


7. Personal Data Processing Terms

We process your personal data from the moment you give your consent or under other circumstances as permitted by law. The duration of storage and processing of your personal data is determined by our obligation to provide you with access to our services, the need to resolve disputes that may arise in connection to the services provided, and other purposes that enable us to conduct our charter activities, including detecting and preventing fraudulent or other illegal actions. Additionally, the storage period depends on the requirements of the Russian Federation's legislation on education and archival affairs. By default, your personal data is processed for three years from the moment your account on the Site is deleted.


We cease the processing of your personal data in any of the following cases:

  • You have withdrawn your consent for us to process personal data or have requested their destruction;

  • The storage period set by law for personal data has expired;

  • The objectives for the personal data processing have been achieved.


8. Your rights

You have the right to:

● Request clarification, blocking or erasure of your personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and to take legal action to protect your rights.

● Request a list of your personal data processed by the Operator and the source of their acquisition

● Request the name and address of the person processing your personal data on behalf of Oksana Nikolaevna Selendeeva

● Request information about the duration of the processing of your personal data, including the retention periods

● Insist that all parties previously informed of inaccurate or incomplete personal data are informed of any exclusions, corrections or additions.

● Withdraw your consent to the processing of personal data

● Object to unlawful actions or omissions in the processing of your personal data to the competent authority for the protection of the rights of data subjects or in court.

● Claim the protection of your rights and legitimate interests, including compensation for damages and/or moral prejudice, in court.


9. Changes in policy

The current version of the Personal Data Processing Policy is published on the website www.coddyschool.com.

Oksana Nikolaevna Selendejeva reserves the right to update this Policy at any time at its own discretion. As a rule, these changes are related to the adaptation of the Policy to changes in the law aimed at further protecting the rights of data subjects.

By continuing to use our services, you agree to the updated policy.


10. Please contact us

If you have any questions about the processing of your personal data, please contact us. Send an email with the subject "Personal data request" to info@coddyschool.com, or write to us at: 105064, Moscow, Nizhniy Susalny Pereulok, Building 5, Structure 19.







Consent to processing of personal data


  1. I hereby - as a fully capable citizen acting in my own interests (hereinafter referred to as the “Subject of Personal Data/Subject”) - give consent to the processing of my personal data by Individual entrepreneur Selendeeva Oksana Nikolaevna, TIN 212901700606, legal address: Russia, 105064, Moscow, Nizhny Susalny Lane, 5, building 19 (referred to in the text as “Operator”) on the following terms:


  1. The operator processes personal data by performing an action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction ,use, depersonalization, blocking, deletion, destruction of personal data.


  1. Personal data is collected by receiving it from the Operator on the websites www.coddyschool.com, www.camp.coddyschool.com, https://summercoddy.ru/, https://coddyintensive.com/, https://franchise.coddyschool. com/ (hereinafter referred to as the “Site”) from the Personal Data Subject.


  1. List of my personal data for the processing of which this consent is given: first name, last name, patronymic, date of birth, gender, marital status, address, email, mobile phone number; technical data that is automatically transmitted by the device with which you use our site, including technical characteristics of the device, IP address, information stored in cookies that were sent to your device, browser information, date and time access to the site, addresses of requested pages and other similar information.


  1. The Operator has the right to process personal data in order to establish and maintain communication between the Subject and the Operator for communication regarding the acquired (purchased) services and services of the Operator.


  1. This consent is valid for an indefinite period. I confirm that I have been notified of the processing of my personal data by the person specified in clause 1 of the Consent and for the purposes specified in clause 5 of the Consent.


  1. The condition for termination of processing of personal data is the receipt by the Operator of a written revocation of this consent. The operator stops processing personal data and destroys it within a period not exceeding 30 days from the date of receipt of the specified review. The operator has the right, after receiving the revocation of this consent, to continue processing personal data without the consent of the subject of personal data if there are grounds specified in paragraphs 2 - 11 of Part 1 of Art. 6, part 2 art. 10 and part 2 of Art. 11 152-FZ “On personal data”.


  1. I have read this agreement in its entirety, including the footnotes, and agree to its terms. Detailed conditions for the processing of personal data are contained in the personal data processing policy, permanently posted on the website https://coddyschool.com/privacy-policy/.


  1. The fact of signing this consent is confirmed by checking the “I agree with the personal data processing policy and consent to the processing of my personal data” checkbox and clicking the “Sign up” button or similar on the Site.


Terms of use

Welcome to CODDY, the international school of programming and design for children!


This User Agreement is a mandatory document for everyone accessing CODDY website and services.


By using our site, you agree to us collecting and processing your personal data in accordance with our Data Processing Policy.


If you disagree with the terms of this Agreement and the Data Processing Policy, please cease using the CODDY school website immediately.


This Agreement is made between you and Oksana Nikolaevna Selendeeva, Individual entrepreneur. The license for educational activities is No. L035-01298-77/00180272, issued on 16 November 2021 by the Department of Education and Science of the City of Moscow. More information about the educational organization can be found at https://coddyschool.com/information/

By using the website, you hereby confirm the following:


  • You have carefully read the Agreement and the Privacy Policy and agree to their terms;

  • You are registering on the Website in your own name or your legal representative is doing so on your behalf;

  • You have all the necessary rights to accept the terms of the Agreement

  • You are a person of full legal capacity capable of accepting the terms of the Agreement. If not, the Website will be used by your legal representative on your behalf. In this case, we assume that all actions taken by you on the Website are done with the consent of your legal representative;

  • Any personal information you provide to us belongs to you or the person for whom you are the legal representative. By providing personal information, you are not infringing the rights of any third party;

  • All information you provide is truthful and accurate for the duration of your use of the Website.

Access to the personal account is granted by entering a login and password. The password can be changed at any time after logging in.


You are responsible for ensuring the security and confidentiality of the data required to use the website. In the event that your authentication data for access to the Website is lost or compromised, as well as if you notice any unauthorized access to your personal account, you are obliged to notify CODDY immediately by any means available. Until such notification is received, all actions performed using your account will be deemed to have been performed by you personally.


What are the restrictions on using the website?


The website and the personal account, including all elements and content, are the intellectual property of the CODDY School, which holds all exclusive rights to all components of the website:


  • audiovisual works;

  • textual and graphic materials;

  • computer programs;

  • trademarks/service marks, logos;

  • Website programming code and/or parts thereof, etc.


By using the Website, you do not acquire any intellectual rights to the aforementioned materials.


You may quote the materials, provided this is expressly permitted by their functionality. For example, you may republish and redistribute our publications. However, you must always provide a link to the website and the relevant material.


When using the website, you are prohibited from:


  • Copying, publishing, transmitting, reproducing or in any other way using the intellectual property of CODDY, except as provided directly in the Agreement or with the written permission of Oksana Nikolaevna Selendeeva;

  • Modifying the software component of the Website in any way;

  • Actions aimed at changing the functionality and operational capacity of the Website;

  • Using information from the Website for commercial activities and for profit;

  • The publication of personal data of third parties on the website without their consent;

  • Placing advertisements, commercial offers, propaganda or other intrusive information in CODDY chats and information rooms;

  • The use of obscene language, the dissemination of information that incites mass riots, extremist activities, participation in (public) mass events that violate the established order, or the use of CODDY for unlawful purposes in any other way;

  • Passing on your authentication data to third parties without the written consent of CODDY;

  • Engaging in political discussions and agitations, using political and religious symbols, making statements containing political, ideological, racist, national or religious hate or hostility motives or hate or hostility motives towards any social group, including discriminatory statements based on gender, race, skin color, nationality, language, origin, wealth, family, social and official status, age, place of residence, religious beliefs, political beliefs, membership or non-membership in public associations;

  • Actions that may lead to the disruption of classes, offending other users and representatives of CODDY.

Our website may contain links to other websites and external services. We are not responsible for the consequences of your use of third party websites, services and software. By accessing such websites and using external services, you fully acknowledge and accept the possible consequences of using these websites and services.

Messages that we can send you

We may send you important notifications during your use of the website. Typically, these notifications may include the following:


  • Confirmation of your use of our services, such as registration on the Website and enrollment in a course;

  • Information that is important for the effective use of the Website, such as announcements about the start of a course and updates about your learning progress;

  • Information about payments you have made on the Website, such as payment reminders and confirmations of completed payments.


We reserve the right to send communications of this nature for the duration of your registration on the Website. The frequency of such communications will depend on your level of active engagement with the Website. Please note that it is not possible to opt out of receiving these types of messages.


By completing the "Registration Form" on our website, you agree to receive information, news and marketing communications. These may include updates on the following topics:


  • Events organized by CODDY or its partners;

  • Current discounts and special offers at CODDY;

  • Available services.


Payment for services


Payment is made cashless via one of the electronic payment services available on the website.


CODDY does not monitor the hardware and software complex of the payment system and is not liable for any errors that may occur during the payment process. 


If errors result in funds being withdrawn without authorization by the payment system provider, the responsibility for refunding the money lies with the provider of the respective electronic payment system.


If you use bank cards issued by foreign banks or if your payment is made via the bank details of a foreign bank:

  • CODDY reserves the right to instruct a payment agent to process payments.

  • The currency of the transaction is the national currency of the paying agent. 

  • The funds received through the Paying Agent will be credited in Russian rubles at the exchange rate set by the Paying Agent on the day the funds are transferred by the Paying Agent. The cost of converting your payment currency into the national currency of the paying agent shall be borne by you. CODDY shall bear the costs of converting the local currency of the paying agent into Russian rubles.

  • CODDY shall not be liable for any consequences arising from exchange rate differences if you pay for access to the Services using bank cards/transfers from foreign banks, including in the event of a refund.


If a payment agent is involved, CODDY guarantees the protection of your bank card data with a PCI DSS certificate.


Responsibility


If you violate the Terms of Service, the rules of the Services or other standards established by Russian legislation or introduced by CODDY, we are entitled to:


  • Suspend or delete your personal account;

  • deny or restrict your access to certain features of the Website

  • withhold the cost of paid but unused lessons.


The above measures may also be applied in the event of an imminent breach on your part.



The website is provided "as is". Any software or hardware errors that result in access to the services not being possible shall be considered force majeure and shall release CODDY from liability for failure to fulfill its obligations under the contract.

CODDY shall not be liable for the non-performance or improper performance of obligations arising from:


  • Unlawful acts of third parties aimed at violating CODDY's or the User's information security or the normal operation of the Website, including unauthorized access to the User's personal account and devices;

  • Unlawful acts of third parties in relation to the User's information due to improper storage of the User's data and other information by the User;

  • Malfunctioning of the Website due to coding errors, viruses, other malicious software or unlawful acts of third parties;

  • The absence of an Internet connection between the User and the Website;

  • Scheduled maintenance work on the Website.


CODDY shall not be liable for the consequences arising from the provision of inaccurate or outdated information by users, including, but not limited to, the inability to use the website and errors in the documents issued.


When processing requests from users, organizations, authorities or other third parties regarding the disclosure of information about a website user, CODDY makes the decision to disclose this information solely on the basis of a legal justification or the user's consent.


CODDY handles such requests with care and ensures that there is a valid reason for the exchange of information. This includes requesting the necessary supporting documents (including those to verify identity). We assume that the copies and originals of the documents provided to CODDY on request are authentic, which demonstrates CODDY's necessary vigilance.

Nevertheless, CODDY cannot completely rule out the risk of fraudulent and other illegal activities in connection with the forgery or falsification of the aforementioned documents.

You are solely responsible for the security of your personal data. If you become aware of any unauthorized access to your information, personal data or authentication data, you are obliged to inform CODDY immediately. If you fail to do so, you will be solely responsible for any adverse consequences resulting from such failure.

Any dispute, controversy or claim arising out of or relating to the formation, execution, modification, termination or invalidity of the Agreement or any other matter relating to the use of the Website shall be settled by negotiation between the parties. The party with claims and/or disagreements must send a message to the other party setting out the points in question.

Please direct all claims or disputes by e-mail to info@coddyschool.com. CODDY will respond to your claims or disputes using the email you provided when you registered on the Site. If you do not receive a response within 30 calendar days from the date of sending the message or if the parties do not reach an agreement on the claims raised, the dispute will be settled in court in accordance with the laws of the Russian Federation.


How do the terms of the agreement change?


We reserve the right to unilaterally change the terms of the agreement at any time. The changes will take effect immediately after the new version of the Agreement is published on the Website. We undertake not to make any material changes or impose any additional burdens.

If you do not agree with the terms of the updated agreement, you must stop using the website immediately. If you do not agree with the new version of the Agreement and have prepaid services that you have not used, you must notify CODDY by sending an email to info@coddyschool.com. By continuing to use the Website, you unconditionally agree to the terms of the new version of the Agreement.


Final provisions


This Agreement and all related legal relationships shall be governed by the laws of the Russian Federation. 


Any notices, communications or documents sent by CODDY via email from domain addresses ending in @coddyschool.com to your email address specified in your personal account, as well as any messages you send to us from the email address specified in your personal account, are legally binding. They create full rights and obligations for both you and CODDY as set out in the Agreement.










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