Personal Data Processing Policy of Fenomen Chess School LLC

This Personal Data Privacy Policy (hereinafter — the Policy) has been developed in accordance with Federal Law No. 152-FZ "On Personal Data" dated 27 July 2006 and applies to all information that Fenomen Chess School LLC (TIN 5406843949, PSRN 1245400036474, registered address: 53 Deputatskaya St., Novosibirsk, Novosibirsk Region, 630099, Russia) (hereinafter — the Operator) may obtain from personal data subjects, including users of the website https://fenomen-kids.ru/ (hereinafter — the Website) and users of the "Fenomen: Chess for Kids" application (hereinafter — the Application). This Policy also applies to the processing of personal data carried out as part of the use of the Operator's mobile application published in application and game stores for various operating systems. Data processing may include the use of advertising SDKs, analytics technologies and other technical solutions necessary for the functioning of the application.

1. Terms

The terms listed below are used in the Policy with the following meanings:

The meaning of terms not defined in the Policy shall be determined in accordance with the legislation of the Russian Federation.

2. Principles of Personal Data processing

2.1. The processing of Personal Data by the Operator is carried out both with and without the use of automation tools in accordance with the following principles:

1. the processing of Personal Data is carried out on a lawful and fair basis;
2. the processing of Personal Data is limited to the achievement of specific, predetermined and lawful purposes;
3. processing of Personal Data incompatible with the purposes of collecting Personal Data is not permitted;
4. the merging of databases containing Personal Data processed for purposes incompatible with each other is not permitted;
5. only Personal Data that meets the purposes of their processing is subject to processing;
6. the content and volume of the processed Personal Data correspond to the stated purposes of processing;
7. the processed Personal Data is not excessive in relation to the stated purposes of their processing;
8. when processing Personal Data, their accuracy, sufficiency and relevance to the purposes of processing are ensured;
9. Personal Data is stored in a form that allows identifying the User (personal data subject) for no longer than the purposes of processing Personal Data require, and it is subject to destruction upon achievement of the purposes of processing or in case of loss of the need to achieve them;
10. Personal Data must be processed in ways that ensure its security, using appropriate technical and organizational measures.

3. Composition of processed Personal Data and purposes of processing

3.1. Personal Data is processed by the Operator for the following purposes:

3.1.1. Providing access to the Website (Application) and its individual functions:

categories of processed Personal Data: Personal Data not related to special and biometric data;

methods of processing and storing Personal Data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, transfer (provision, access), depersonalization, blocking, deletion, destruction;

terms of processing and storing Personal Data: until the purposes of processing Personal Data are achieved;

procedure for destroying Personal Data: deletion of Personal Data from electronic and/or physical media or destruction of physical media containing Personal Data.

3.1.2. Promotion of the Operator's goods, works and services:

list of processed Personal Data: full name, email address, contact phone number, gender;

categories of processed Personal Data: Personal Data not related to special and biometric data;

terms of processing and storing Personal Data: until the purposes of processing Personal Data are achieved;

methods of processing and storing Personal Data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, transfer (provision, access), depersonalization, blocking, deletion, destruction;

3.1.3. For statistical and research purposes:

list of processed Personal Data: full name, date of birth, email address, contact phone number;

categories of processed Personal Data: Personal Data not related to special and biometric data;

terms of processing and storing Personal Data: until the purposes of processing Personal Data are achieved;

methods of processing and storing Personal Data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, transfer (provision, access), depersonalization, blocking, deletion, destruction;

4. Conditions for processing Personal Data

4.1. The processing of Personal Data by the Operator is permitted in the following cases:

1. where the User has given consent to the processing of their Personal Data;
2. for the conclusion and performance of a contract to which the Subject is a party, beneficiary or guarantor;
3. for statistical and research purposes, except for the purposes specified in Art. 15 of 152-FZ, provided that the Personal Data is depersonalized;
4. where there are grounds provided for by the legislation of the Russian Federation that allow the processing of Personal Data in the absence of the User's consent.

4.2. Personal Data may be transferred to the Operator's partners for the performance of obligations provided for by the contract between the Operator and the Users. In other cases, Personal Data is transferred to the Operator's partners only with the User's consent to the processing of Personal Data.

4.3. The Operator does not process Personal Data related to special categories and concerning racial and ethnic origin, political views, religious or philosophical beliefs, health, intimate life, or membership in public associations, nor biometric Personal Data, except in cases expressly provided for by the legislation of the Russian Federation.

4.4. When collecting Personal Data, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of Personal Data of Users who are citizens of the Russian Federation using databases located in the territory of the Russian Federation, except in cases provided for by the legislation of the Russian Federation.

5. User rights

5.1. With respect to their Personal Data, the User has the right to:

1. make a decision on providing their Personal Data to the Operator and third parties and give consent to their processing freely, of their own will and in their own interest;
2. withdraw their consent to the processing of Personal Data by sending the Operator a corresponding notification;
3. receive information from the Operator concerning the processing of Personal Data by sending a corresponding request;
4. require the Operator to clarify Personal Data, block or destroy it if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purposes of processing;
5. require the cessation of processing of Personal Data for the purpose of promoting goods, works and services on the market by making direct contact with them by means of communication;
6. appeal against the Operator's actions or inaction to the authorized body for the protection of the rights of personal data subjects or in court;
7. exercise other rights provided for by the legislation of the Russian Federation.

5.2. To exercise the rights provided for in clauses 5.1.2–5.1.5 of the Policy, the User must send a corresponding request (demand, notification) to the Operator's address or the Operator's email specified in Section 10 of the Policy. The request (demand, notification) must contain the information provided for in Part 3 of Art. 14 of Federal Law No. 152-FZ "On Personal Data" dated 27 July 2006.

6. Rights and obligations of the Operator

6.1. The Operator undertakes to process Personal Data in accordance with the legislation of the Russian Federation and the Operator's local regulations.

6.2. With respect to the User's Personal Data, the Operator undertakes to maintain its Confidentiality, except in cases provided for by the legislation of the Russian Federation.

6.3. The Operator is obliged to take measures necessary and sufficient to ensure the fulfillment of obligations provided for by the legislation of the Russian Federation. The Operator independently determines the composition and list of such measures.

6.4. The Operator is obliged to provide the User or their representative with information about the processing of Personal Data relating to the respective User, as well as to provide the opportunity to review this Personal Data free of charge, in the manner and within the time limits established by the legislation of the Russian Federation.

6.5. If unlawful processing of Personal Data is detected, the Operator is obliged to stop processing such Personal Data. If it is impossible to ensure the lawfulness of the processing of Personal Data, the Operator is obliged to destroy or ensure the destruction of such Personal Data in the manner and within the time limits established by the legislation of the Russian Federation.

6.6. If a fact of inaccuracy of personal data is detected, the Operator is obliged to block or ensure the blocking of such Personal Data and to clarify or ensure its clarification in the manner and within the time limits established by the legislation of the Russian Federation.

6.7. The Operator performs other obligations provided for by the legislation of the Russian Federation.

6.8. The Operator has the right to transfer the User's Personal Data to third parties with the User's consent.

6.9. The Operator has the right to transfer the User's Personal Data to third parties without the User's consent in the following cases:

1. the transfer is necessary as part of the Users' use of the Website, the performance of a contract on the use of the Website, or the performance of other contracts of the Operator with Users;
2. the transfer is made to state authorities, including bodies of inquiry and investigation, and local self-government bodies at their reasoned request that complies with the legislation of the Russian Federation;
3. in other cases expressly provided for by the legislation of the Russian Federation.

7. Cross-border transfer of Personal Data

7.1. The Operator has the right to carry out cross-border transfer of the User's Personal Data to the territory of foreign states that ensure adequate protection of the rights of Personal Data subjects, except in cases where such transfer is prohibited or restricted in order to protect the foundations of the constitutional order of the Russian Federation, morality, health, the rights and legitimate interests of citizens, and to ensure the country's defense and state security.

8. Security of Personal Data

8.1. The Operator applies measures to ensure the security of the User's Personal Data.

8.2. Third parties may process the User's Personal Data strictly in accordance with the Operator's instructions and in cases where they take protective measures with respect to Personal Data similar to those provided for by the Policy.

8.3. The Operator applies appropriate security measures to prevent accidental loss, use, or availability of the User's Personal Data for unauthorized use, modification, or disclosure.

8.4. The Operator limits access to the User's Personal Data only to those employees, agents, contractors and other third parties who require it in connection with business purposes or purposes provided for by the legislation of the Russian Federation.

8.5. Access to Information systems containing Personal Data is provided by a system of passwords. Passwords are set by authorized employees of the Operator and individually communicated to the Operator's employees who have access to Personal Data.

8.6. The Operator uses procedures for handling any suspected violations of security requirements regarding Personal Data, and also notifies the User and the relevant regulatory authorities of such violations in cases where this is required by the legislation of the Russian Federation.

9. Other provisions

9.1. The law of the Russian Federation applies to this Policy and to the relations between the User and the Operator arising in connection with the application of the Policy.

9.2. All possible disputes between the User and the Operator related to the Policy are subject to resolution in accordance with the legislation of the Russian Federation.

9.3. If, for one reason or another, one or more provisions of the Policy are declared invalid, this does not affect the validity of the remaining provisions of the Policy.

9.4. The User undertakes to independently monitor changes to the Policy by reviewing the current version.

10. Operator's contact information

Fenomen Chess School LLC

TIN: 5406843949

PSRN: 1245400036474

Registered address: 53 Deputatskaya St., Novosibirsk, Novosibirsk Region, 630099, Russia

Email: phenomenon.chess.school@gmail.com