1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Shitova Yulia Anatolyevna, (Art Education Group), TIN: 772494661573 (hereinafter - the Operator).
1.1. The Operator's most important goal and condition for carrying out its activities is to observe the rights and freedoms of a person and a citizen when processing their personal data, including protecting the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website located at https://apm-education.com and https://apm-education.ru

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (unless processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://apm-education.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine the belonging of personal data to a specific User or other personal data subject without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://apm-education.com.
2.9. Personal data permitted for dissemination by the personal data subject — personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted for dissemination by the personal data subject in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://apm-education.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks or providing 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 a state authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as sends a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— to provide the personal data subject, at their request, with information concerning the processing of their personal data;
— to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— terminate the transfer (distribution, provision, access) of personal data, terminate the processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to fulfill other obligations provided for by the Personal Data Law.

4. Main rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to demand from the operator the clarification of their personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also to take measures provided by law to protect their rights;
— to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop the processing of personal data;
— to appeal to the authorized body for the protection of personal data subjects' rights or to the court against unlawful actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for incompatible purposes.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated processing purposes. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Processing purpose 1
Processing of personal data for communication with the client, responding to their incoming request, providing consultations on services, as well as performing actions aimed at concluding a contract.
Personal data:

• last name, first name, patronymic
• email address
• phone numbers

Legal grounds:

• contracts concluded between the operator and the personal data subject
• consent of the personal data subject to the processing of personal data by means of a corresponding mark of consent in the form

Types of personal data processing:

• collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
• sending newsletters to the email address
• use of personal data to contact the client by phone number and/or in messengers

Processing purpose 2
Collection and processing of cookies to ensure the correct functioning of the site, improve the quality of the service, conduct statistics, analytics, and personalize the user experience.
Personal data:

• cookies
• browser and device data
• information about visited pages, date and time of access, user actions on the site, as well as anonymized web analytics data.

Legal grounds:

• consent of the personal data subject
• Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ

Types of personal data processing:

• collection of cookies, recording, systematization and storage of cookies in logs and analytical systems
• use of cookies for website functionality and analytics
• transfer of anonymized data to analytical services

Purpose of processing 3
Processing of personal data for sending advertising, informational and news materials by e-mail with the separate consent of the personal data subject.
Personal data:

• last name, first name, patronymic
• email address
• phone numbers

Legal grounds:

• consent of the personal data subject to receive advertising materials (separate consent via checkbox)
• Federal Law "On Advertising" No. 38-FZ
• Federal Law "On Personal Data" No. 152-FZ

Types of personal data processing:

• collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
• sending promotional materials to the email address

7. Conditions for processing personal data

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 the goals stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, 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, as well as for the conclusion of a contract at the initiative of the personal data subject or 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 operator's or third parties' rights and legitimate interests, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which an unlimited circle of persons has been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for collecting, storing, transferring, and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@apm-education.com with the subject line "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@apm-education.com with the subject line "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject, or a request to terminate personal data processing, as well as the detection of unlawful personal data processing.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with and/or without the transfer of the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before commencing activities involving cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can receive any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email info@apm-education.com.
12.2. 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.
12.3. The current version of the Policy is freely available on the Internet at https://apm-education.com/en/privacy and https://apm-education.ru/privacy


Revision date: 12/09/2025