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Personal Data Processing Policy

1. General Provisions

This personal data processing policy defines the procedure for processing personal data and measures to ensure the security of personal data of Lana Invest Limited (hereinafter referred to as the Operator).


  1. The Operator sees respect for and observance of human rights and freedoms as her overriding priority and condition of her business when processing personal data of citizens, including protection of personal privacy, personal and family secrets.
  2. This Operator's policy of personal data processing (hereinafter referred to as the Policy) applies to all information about visitors of the website http://lanainvest.com (heinafter the Website) that the Operator may obtain.

2. General Definitions Used in the Policy



  1. Automated Personal Data Processing is personal data processing by means of computers;
  2. Blocking of Personal Data is temporary termination of personal data processing (except in cases where the processing is necessary to obtain more accurate personal data);
  3. Website is a collection of graphic and information materials and computer programs and databases that ensure their availability on the Internet at the Website network address;
  4. Personal Data Information System is a collection of personal data contained in databases and information technologies and technical means that ensure their processing;
  5. Depersonalization of Personal Data is actions which make it impossible to identify a certain User or data subject as the data owner without additional information;
  6. Personal data processing is any action (operation) or combination of actions (operation) with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating and modification), extraction, use, transfer (distribution, placing at smb's disposal, access), depersonalization, blocking, deletion and destruction or personal data, both with and without the use of automation technologies.
  7. Operator is a state authority, a municipal authority, a juridical or natural person that organizes and (or) performs personal data processing and determines the purposes of personal data processing, the personal data structure to be processed and actions (operations) with personal data independently or together with other persons;
  8. Personal Data is any information which is related to an identified or identifiable User of the https://school.lanacourse.ru/main website expressly or by implication;
  9. User is any visitor of the Website;
  10. Placing Personal Data at smb's Disposal is actions aimed at disclosing personal data to a certain person or a certain set of persons;
  11. Distribution of Personal Data is any actions aimed at disclosing personal data to an indefinite set of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in the mass media, posting in information and telecommunications networks or otherwise providing access to personal data;
  12. Cross-Border Transfer of Personal Data is the transfer of personal data to a foreign country to an authority of a foreign state, a foreign natural or juridical person;
  13. Destruction of Personal Data is any actions which turn personal data irretrievably destroyed and make it impossible to restore the content of personal data in the personal data information system and (or) which destroy the material media bearing the personal data.

3. The Operator may process the following personal data of the User:


  1. Surname, given name, patronymic;
  2. Phone number;
  3. Email;
  4. The Website also features collection and processing of anonymous data about visitors (including cookies) using web analytics services (Yandex.Metrica, Google Analytics, etc.).
  5. The above-mentioned data are jointly referred as the Personal Data in the text below.

4. Purposes of Personal Data Processing



  1. The purpose of processing the User's personal data is concluding, performing and terminating civil contracts; providing the User with access to the services, information and/or materials contained on the Website; clarifying order details.
  2. The Operator is also entitled to send notifications about new products and services, special offers and various events to the User. The User may always refuse to receive information messages by sending an email marked "Disable notifications of new products and services and special offers" to the Operator to the email support@lanacourse.ru.
  3. Depersonalized User data collected through web analytics services are used to collect information about User actions on the website and improve the quality and content of the website.

5. Legal Reasons for Personal Data Processing



  1. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the Website. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.
  2. The Operator processes depersonalized data of the User if this is enabled by the User's browser settings (saving cookies and using JavaScript technology are enabled).

6. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of the personal data processed by the Operator is ensured through implementing legal, organizational and technical measures necessary to fully comply with the requirements of applicable personal data protection laws.



  1. The Operator ensures personal data security and takes all possible measures to prevent unauthorized persons from accessing the personal data.
  2. The User's personal data shall never be transferred to third parties under any circumstances except for execution of applicable laws.
  3. If the User finds any inaccuracies in personal data, they can update the data independently by sending a notification marked "Personal data update" to the Operator at the Operator's email support@lanacourse.ru.
  4. The duration of personal data processing is unlimited. The User can withdraw their consent to personal data processing at any time by sending a notification marked "Withdrawal of consent to personal data processing" to the Operator's e-mail support@lanacourse.ru

7. Cross-Border Transfer of Personal Data



  1. Before starting cross-border transfer of personal data, the Operator shall make sure that the foreign state to which the personal data are to be transferred provides reliable protection of the rights of data subjects.
  2. Cross-border transfer of personal data in foreign states that do not meet the above requirements can only be performed if the data subject gave their written consent to the cross-border transfer of their personal data and/or if an agreement to which the data subject is a party is performed.

8. Final Provisions



  1. The User can get any explanations on the issues related to processing of their personal data by contacting the Operator via e-mail support@lanacourse.ru.
  2. This document will contain any changes to the Operator's personal data processing policy. The policy shall be valid indefinitely until it is replaced with a new version.