Personal Data Processing Policy
1. General Provisions
1.1. This Personal Data Processing Policy defines the procedure for processing and protecting the personal data of users of alexzueva.ru, clients, potential clients, newsletter subscribers and other individuals who interact with Individual Entrepreneur Alexandra Vadimovna Zueva.

1.2. The Operator processes personal data in accordance with Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 and other applicable laws and regulations of the Russian Federation.

1.3. By using the website, filling in forms, sending requests, purchasing the Operator’s products or interacting with the Operator in any other way, the user confirms that they have read this Policy.

1.4. The Operator’s website, products and services are intended for individuals aged 18 and over. By filling in a form, submitting a request or purchasing a product, the user confirms that they are of legal age and have full legal capacity.

1.5. This English version of the Policy is provided for the convenience of English-speaking users. In case of any discrepancy between the Russian and English versions, the Russian version shall prevail.

2. Personal Data Operator
2.1. The personal data operator is Individual Entrepreneur Alexandra Vadimovna Zueva, Taxpayer Identification Number / INN 667478974868, Primary State Registration Number of Individual Entrepreneur / OGRNIP 326965800161467, location: Russian Federation, Yekaterinburg.

2.2. For any questions related to the processing of personal data, the user may contact the Operator by email: alexxzueva@yandex.ru

3. Categories of Personal Data Subjects
3.1. The Operator may process the personal data of website visitors, users who fill in forms on the website, potential clients, clients, purchasers of the Operator’s products, newsletter subscribers and users who interact with the Operator through the website, email or Telegram.

4. Personal Data Processed
4.1. The Operator may process the following personal data: first name, last name, email address, phone number, Telegram username, Telegram ID, Telegram display name, information about the request, selected product, plan or course, payment information, including payment status, amount, date, payment status, order or purchased product, information about access to the course, contents of messages sent through website forms, email or Telegram, answers to quizzes, questionnaires or surveys, information about the user’s experience with pronunciation work, learning goals, interests and needs, information about which of the Operator’s products the user has previously purchased or taken, information about the source of referral to the website, information about consent or refusal to receive informational and advertising emails, audio and video recordings of speech voluntarily submitted by the user during the learning process, as well as technical data that may be automatically transmitted when using the website, including IP address, browser information, device information, operating system information, cookies, date and time of website visit.

4.2. The Operator does not receive or store users’ bank card details. Such data is processed by the bank, payment service provider or acquiring organization.

4.3. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs or health.

4.4. Audio and video recordings of the user’s speech are used only for pronunciation analysis, feedback, learning support and progress assessment. The Operator does not use such materials to identify the user.

4.5. The Operator does not publish the user’s audio, video, text or other learning materials in open sources, social media, advertising materials, testimonials or case studies without the user’s separate consent.

5. Purposes of Personal Data Processing
5.1. The Operator processes personal data for the following purposes: processing requests for courses, consultations and other products, providing a free guide and other free materials, analysing quiz, questionnaire and survey answers, contacting the user regarding a request, purchase, payment or learning process, accepting and recording payments, providing access to courses, materials, closed Telegram channels and other products, supporting the learning process, providing feedback and checking assignments, maintaining a client database and history of interaction with clients, complying with the laws of the Russian Federation, maintaining accounting, tax and other mandatory records, and protecting the Operator’s rights and legitimate interests.

5.2. Informational and advertising messages about new products, launches, projects, special terms and early bird offers are sent only if the user has given separate consent.

6. Legal Grounds for Processing
6.1. The Operator processes personal data on the basis of the user’s consent to the processing of personal data, the conclusion and performance of a contract between the user and the Operator, compliance with obligations established by the laws of the Russian Federation, protection of the Operator’s rights and legitimate interests, and the user’s separate consent to receive informational and advertising messages.

6.2. The user’s inactivity shall not be considered consent to the processing of personal data.

7. Actions Performed with Personal Data
7.1. The Operator may perform the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification, updating, modification, use, transfer, provision of access, anonymization, blocking, deletion and destruction.

7.2. Personal data may be processed both with and without the use of automated means.

8. Services and Persons Involved in Personal Data Processing
8.1. For the processing of personal data, the Operator may use Tilda / Tilda CRM for the operation of the website, forms and storage of requests, YouGile for maintaining the client database, client support and organizing work with requests, UniSender for email newsletters to users who have separately agreed to receive them, Yandex Mail for email correspondence, Telegram for communication with users, receiving learning materials, providing access to the closed Telegram channel and administering such access, Zenclass for hosting the course, providing access to learning materials and supporting the learning process, as well as a bank, payment service provider or acquiring organization for accepting and processing payments.

8.2. The Operator may entrust the processing of personal data to third parties if this is necessary to achieve the purposes of processing, provided that such parties maintain confidentiality and comply with personal data protection laws.

8.3. Access to certain personal data of clients may be granted to contractors, teachers, coaches and other persons engaged by the Operator and involved in the provision of services and learning support. Such access is granted only to the extent necessary to perform the relevant tasks.

8.4. Personal data may be provided to government authorities, courts and other authorized persons in cases and in the manner provided for by the laws of the Russian Federation.

9. Localization and Cross-border Transfer
9.1. The Operator processes the personal data of citizens of the Russian Federation using databases located within the territory of the Russian Federation.

9.2. The Operator does not carry out cross-border transfer of personal data.

10. Newsletter
10.1. The Operator sends informational and advertising messages only to users who have separately expressed their consent to receive such messages.

10.2. The newsletter may contain information about new products, launches, the Operator’s projects, special terms, early access and early bird offers.

10.3. The user may unsubscribe from the newsletter at any time by using the unsubscribe link in the email or by sending a request to: alexxzueva@yandex.ru

10.4. Unsubscribing from the newsletter does not affect the receipt of technical and organizational messages related to a request, purchase, payment, access or learning process.

11. Cookies and Technical Data
11.1. The website may use technical cookies necessary for the correct operation of the website, security and saving user settings.

11.2. The Operator does not use cookies for advertising profiling of users unless otherwise expressly stated on the website.

11.3. If the Operator connects analytics systems, advertising pixels or other similar tools in the future, information about this will be reflected in this Policy or in a separate notice on the website.

12. Terms of Processing and Storage of Personal Data
12.1. Personal data is processed and stored for the period necessary to achieve the purposes of processing specified in this Policy.

12.2. Client data may be stored for the period necessary to perform the contract, provide access to purchased products, support the learning process, maintain the history of interaction, confirm the fact that services were provided, comply with legal requirements and protect the Operator’s rights.

12.3. Newsletter subscriber data is processed until the user unsubscribes from the newsletter or withdraws consent, unless otherwise provided for by the laws of the Russian Federation.

12.4. If consent is withdrawn, the Operator stops processing personal data and destroys it within the period established by the laws of the Russian Federation, except in cases where further processing is permitted by the laws of the Russian Federation, necessary for the performance of a contract, compliance with legal requirements, accounting or tax records, or protection of the Operator’s rights and legitimate interests.

12.5. Personal data is destroyed by deleting it from the information systems and services used by the Operator, as well as by destroying physical media, if any.

13. Protection of Personal Data
13.1. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions.

13.2. Access to personal data is granted only to those persons who need it to perform tasks related to the provision of services, processing of requests, learning support, technical support, record keeping or compliance with legal requirements.

14. User Rights
14.1. The user has the right to receive information about the processing of their personal data, request clarification, blocking or destruction of personal data, withdraw consent to the processing of personal data, unsubscribe from informational and advertising messages, and send the Operator a request related to the processing of personal data.

14.2. To exercise their rights, the user may contact the Operator by email: alexxzueva@yandex.ru

14.3. The Operator reviews user requests within the time limits established by the laws of the Russian Federation and may request additional information necessary to confirm the identity of the applicant and properly review the request.

15. Changes to the Policy
15.1. The Operator has the right to amend this Policy. The new version of the Policy comes into force from the moment it is published on the website, unless otherwise stated in the new version.

15.2. The current version of the Policy is available on alexzueva.ru

16. Contacts
16.1. For any questions related to the processing of personal data, the user may contact the Operator by email: alexxzueva@yandex.ru

17. Document Information
17.1. Date of publication of this version of the Policy: 29.06.29
17.2. The current version of the Policy is available on alexzueva.ru.