Privacy Policy
1. General Provisions
The Privacy Policy is an integral part of the Terms of Service and explains what personal data of Users and their clients is collected and stored by Eigenson Dmitrii (hereinafter referred to as the Operator) when using the website https://ne-institute.com.
This Privacy Policy (hereinafter — Privacy Policy, Policy) is developed in accordance with the requirements of the Federal Decree Law UAE No. 45/2021 on the Protection of Personal Data and the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR) (hereinafter collectively — Law), is adopted and in force by the Administration (hereinafter — Administration, we).
This Privacy Policy (hereinafter referred to as the Policy) is prepared in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ “On Personal Data”
1.1. The Operator sets the protection of human and citizen rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets, as the most important goal and condition of its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://ne-institute.com.
2. Basic Terms 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 suspension of personal data processing (except for cases when processing is necessary for clarifying personal data).
2.3. Website – a set of graphical and informational materials, as well as computer software and databases, ensuring their availability on the Internet at the network address https://ne-institute.com.
2.4. Information system of personal data – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or other personal data subject without additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or physical person, independently or jointly with others, 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, and actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website https://ne-institute.com.
2.9. User – any visitor to the website https://ne-institute.com.
2.10. Providing personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.11. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the media, information and telecommunications networks, or providing access to personal data in any other way.
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.13. Destruction of personal data – actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the information system and/or destruction of the physical carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the subject’s consent in case of the subject withdrawing consent to the processing of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary to ensure the fulfillment of obligations provided by the Personal Data Law unless otherwise provided by law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with current legislation of the Russian Federation;
— respond to inquiries and requests of personal data subjects and their legal representatives in compliance with the requirements of the Personal Data Law;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions;
— terminate processing and destroy personal data as per the requirements of the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information related to the processing of their personal data, except for cases provided by federal laws. The Operator provides the data in an accessible form, and it must not contain personal data relating to other subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures to protect their rights as prescribed by law;
— set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data at any time and request the termination of data processing;
— appeal to the authorized body for the protection of the rights of personal data subjects or to the court for unlawful actions or inaction of the Operator during the processing of personal data;
— exercise other rights provided 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 clarifying (updating, changing) their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined, and legitimate purposes. It is not allowed to process personal data in a manner incompatible with the purposes of personal data collection.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data concerning the stated purposes of their processing is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data concerning the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their implementation for removing or clarifying incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless a storage period for personal data is established by federal law or a contract. Processed personal data is destroyed or depersonalized upon achieving processing purposes or in case of a loss of necessity in achieving these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— Informing the User by sending emails.
Personal data:
— Last name, first name, patronymic;
— Email address;
— Phone numbers.
Legal grounds:
— Federal Law “On Information, Information Technologies, and Information Protection” of 27.07.2006 N 149-FZ.
Types of personal data processing:
— Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out 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 objectives stipulated by international treaties of the Russian Federation or laws for the exercise of the Operator’s functions, powers, and duties.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or act of another authority or official enforceable under Russian Federation law on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract on 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 to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant objectives, provided that it does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data is carried out for personal data accessible to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as public personal data).
7.7. The processing of personal data is carried out in cases where the publication or mandatory disclosure of personal data is required in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will not be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can independently update them by sending a notification to the Operator’s email address instituteneuro7@gmail.com marked “Update of Personal Data.”
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected unless otherwise provided by the contract or current legislation. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to instituteneuro7@gmail.com marked “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 parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the specified documents should be familiarized with. The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
8.6. The prohibitions set by the personal data subject on the transfer (except for providing access) and processing conditions (except for obtaining access) of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian Federation law.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than is required by the purposes of personal data processing unless a storage period for personal data is established by federal law, the contract under which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating personal data processing may be the achievement of personal data processing purposes, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, or a request for termination of personal data processing, as well as the identification of unlawful personal data processing.
9. Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated personal data processing with the receipt and/or transfer of received information via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. The Operator, before commencing the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification about the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain the necessary information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters of interest related to the processing of their personal data by contacting the Operator via email at instituteneuro7@gmail.com.
12.2. This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at https://ne-institute.com/privacyeng
The Privacy Policy is an integral part of the Terms of Service and explains what personal data of Users and their clients is collected and stored by Eigenson Dmitrii (hereinafter referred to as the Operator) when using the website https://ne-institute.com.
This Privacy Policy (hereinafter — Privacy Policy, Policy) is developed in accordance with the requirements of the Federal Decree Law UAE No. 45/2021 on the Protection of Personal Data and the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR) (hereinafter collectively — Law), is adopted and in force by the Administration (hereinafter — Administration, we).
This Privacy Policy (hereinafter referred to as the Policy) is prepared in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ “On Personal Data”
1.1. The Operator sets the protection of human and citizen rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets, as the most important goal and condition of its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://ne-institute.com.
2. Basic Terms 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 suspension of personal data processing (except for cases when processing is necessary for clarifying personal data).
2.3. Website – a set of graphical and informational materials, as well as computer software and databases, ensuring their availability on the Internet at the network address https://ne-institute.com.
2.4. Information system of personal data – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or other personal data subject without additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or physical person, independently or jointly with others, 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, and actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website https://ne-institute.com.
2.9. User – any visitor to the website https://ne-institute.com.
2.10. Providing personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.11. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the media, information and telecommunications networks, or providing access to personal data in any other way.
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.13. Destruction of personal data – actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the information system and/or destruction of the physical carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the subject’s consent in case of the subject withdrawing consent to the processing of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary to ensure the fulfillment of obligations provided by the Personal Data Law unless otherwise provided by law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with current legislation of the Russian Federation;
— respond to inquiries and requests of personal data subjects and their legal representatives in compliance with the requirements of the Personal Data Law;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions;
— terminate processing and destroy personal data as per the requirements of the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information related to the processing of their personal data, except for cases provided by federal laws. The Operator provides the data in an accessible form, and it must not contain personal data relating to other subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures to protect their rights as prescribed by law;
— set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data at any time and request the termination of data processing;
— appeal to the authorized body for the protection of the rights of personal data subjects or to the court for unlawful actions or inaction of the Operator during the processing of personal data;
— exercise other rights provided 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 clarifying (updating, changing) their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined, and legitimate purposes. It is not allowed to process personal data in a manner incompatible with the purposes of personal data collection.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data concerning the stated purposes of their processing is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data concerning the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their implementation for removing or clarifying incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless a storage period for personal data is established by federal law or a contract. Processed personal data is destroyed or depersonalized upon achieving processing purposes or in case of a loss of necessity in achieving these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— Informing the User by sending emails.
Personal data:
— Last name, first name, patronymic;
— Email address;
— Phone numbers.
Legal grounds:
— Federal Law “On Information, Information Technologies, and Information Protection” of 27.07.2006 N 149-FZ.
Types of personal data processing:
— Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out 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 objectives stipulated by international treaties of the Russian Federation or laws for the exercise of the Operator’s functions, powers, and duties.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or act of another authority or official enforceable under Russian Federation law on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract on 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 to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant objectives, provided that it does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data is carried out for personal data accessible to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as public personal data).
7.7. The processing of personal data is carried out in cases where the publication or mandatory disclosure of personal data is required in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will not be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can independently update them by sending a notification to the Operator’s email address instituteneuro7@gmail.com marked “Update of Personal Data.”
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected unless otherwise provided by the contract or current legislation. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to instituteneuro7@gmail.com marked “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 parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the specified documents should be familiarized with. The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
8.6. The prohibitions set by the personal data subject on the transfer (except for providing access) and processing conditions (except for obtaining access) of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian Federation law.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than is required by the purposes of personal data processing unless a storage period for personal data is established by federal law, the contract under which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating personal data processing may be the achievement of personal data processing purposes, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, or a request for termination of personal data processing, as well as the identification of unlawful personal data processing.
9. Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated personal data processing with the receipt and/or transfer of received information via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. The Operator, before commencing the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification about the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain the necessary information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters of interest related to the processing of their personal data by contacting the Operator via email at instituteneuro7@gmail.com.
12.2. This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at https://ne-institute.com/privacyeng