Current version
This is an English translation, provided so that you can read the document. The legally binding text is the Russian original — switch the interface language to Russian to read it. If the two differ, the Russian text prevails.
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the "Personal Data Law") and sets out the procedure for processing personal data and the measures taken to keep personal data secure by Individual Entrepreneur Evgeniy Vladimirovich Kolesnikov (the "Operator").
1.1. The Operator holds as its most important aim and as a condition of its activity the observance of the rights and freedoms of the person and the citizen in the processing of their personal data, including protection of the rights to privacy and to personal and family secrecy.
1.2. This policy of the Operator concerning the processing of personal data (the "Policy") applies to all information the Operator may obtain about visitors to the website https://platform.johnnykole.com.
2.1. Automated processing of personal data — processing of personal data by means of computing equipment.
2.2. Blocking of personal data — temporary cessation of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — the body of graphic and informational materials, together with the computer programs and databases that make them available on the internet at the network address https://platform.johnnykole.com.
2.4. Personal data information system — the body of personal data held in databases together with the information technologies and technical means that process them.
2.5. Depersonalisation of personal data — actions as a result of which it is impossible, without using additional information, to determine that personal data belongs to a particular User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, with or without the use of automation, including collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or natural person which, alone or jointly with others, organises and/or carries out the processing of personal data, and which also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed on the personal data.
2.8. Personal data — any information relating directly or indirectly to a determined or determinable User of the website https://platform.johnnykole.com.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited range of persons has been granted by the personal data subject through giving consent to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law (hereinafter, personal data permitted for distribution).
2.10. User — any visitor to the website https://platform.johnnykole.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a particular person or a particular range of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indeterminate range of persons (transfer of personal data), or at making personal data known to an unlimited range of persons, including publishing personal data in the mass media, placing it in information and telecommunications networks, or granting access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign natural or legal person.
2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably, with no possibility of further restoring the content of the personal data in the personal data information system, and/or the material carriers of the personal data are destroyed.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who have given the Operator inaccurate information about themselves, or information about another personal data subject without that subject's consent, bear liability in accordance with the legislation of the Russian Federation.
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of collecting the personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data processed for purposes that are incompatible with one another.
5.4. Only personal data that answers the purposes of its processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excess of the personal data processed in relation to the stated purposes of processing is not permitted.
5.6. When personal data is processed, its accuracy and sufficiency are ensured, and where necessary its currency in relation to the purposes of processing. The Operator takes, and/or ensures that there are taken, the measures necessary to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing the personal data subject to be determined for no longer than the purposes of processing require, unless a storage period for the personal data is set by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalised once the purposes of processing are achieved, or where the need to achieve those purposes is lost, unless federal law provides otherwise.
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data |
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| Legal grounds | Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and the Protection of Information" |
| Types of personal data processing |
|
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and duties placed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, for the execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, and for the conclusion of a contract at the initiative of the personal data subject, or of a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and lawful interests of the operator or of third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby infringed.
7.6. There is processing of personal data to which access by an unlimited range of persons has been granted by the personal data subject or at their request (hereinafter, publicly available personal data).
7.7. There is processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
The security of the personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to meet in full the requirements of the current legislation on the protection of personal data.
8.1. The Operator ensures that personal data is kept safe and takes every possible measure to exclude access to personal data by unauthorised persons.
8.2. A User's personal data will never, under any circumstances, be transferred to third parties, except in cases connected with compliance with current legislation, or where the personal data subject has given the Operator consent to transfer the data to a third party in order to perform obligations under a civil-law contract.
8.3. If inaccuracies are found in personal data, the User may update it themselves by sending the Operator a notice to the Operator's email address privacy@johnnykole.com marked "Updating of personal data".
8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or by current legislation. The User may at any moment withdraw their consent to the processing of personal data by sending the Operator a notice by email to the Operator's email address privacy@johnnykole.com marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarise themselves with those documents in good time. The Operator bears no responsibility for the actions of third parties, including the service providers named in this clause.
8.6. Prohibitions set by the personal data subject on transfer (other than granting access), and on the processing or the conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of the personal data.
8.8. The Operator stores personal data in a form allowing the personal data subject to be determined for no longer than the purposes of processing require, unless a storage period for the personal data is set by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for ceasing the processing of personal data may be the achievement of the purposes of processing, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject or a demand that the processing of personal data cease, and also the discovery of unlawful processing of personal data.
9.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained over information and telecommunications networks.
10.1. Before beginning any activity involving the cross-border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such a notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, and from the foreign natural or legal persons, to whom the cross-border transfer of personal data is planned.
The Operator and other persons who have obtained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the personal data subject, unless federal law provides otherwise.
12.1. A cookie is a small piece of data that a site saves in a visitor's browser. The Operator uses cookies only for the working of the site itself and does not pass them to third parties.
12.2. The following cookies are used on the site:
| Purpose | Description | Storage period |
|---|---|---|
| Sign-in session | Allows you to stay signed in after entering by link or password. Without it, signing in to the platform is impossible. | Until the session ends |
| Partner link | Remembers on whose recommendation the visitor came to the platform, so that their mentor is correctly determined. | 60 days |
| Cookie notice | Remembers that the visitor has read the notice, so that it is not shown again. | 1 year |
| Interface language | Remembers the language chosen with the switcher, so that the platform and the emails come in that language. | 1 year |
12.3. Third-party web analytics systems and advertising trackers are not used on the site.
12.4. A visitor may at any moment delete saved cookies or forbid their saving in their browser settings. With cookies disabled, signing in to the platform and some of its functions will not be available.
13.1. A User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at privacy@johnnykole.com.
13.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
13.3. The current version of the Policy is located in open access on the internet at https://platform.johnnykole.com/privacy.