Skymath Personal Data Processing Policy
Date of change
25.05.2022
Responsible
Rustam Klepcha
Summary of changes
Updating of the list of processed personal data
Table of contents
1. SCOPE OF APPLICATION
2. PURPOSES AND LEGAL BASIS FOR PROCESSING
2.3. Legal Basis for Personal Data Processing
3. PROCEDURE AND CONDITIONS FOR PERSONAL INFORMATION PROCESSING
3.1. Information Collecting
3.2. Obtaining the Subject’s Consent to Personal Information Processing
3.3. Description of Information Processed on the Basis of the Consent
3.4. Storage Conditions
3.5. Storage Period
3.6. Terms of Destruction or Pseudonymisation
4. UPDATING, RECTIFICATION, DELETION AND DESTRUCTION OF DATA, RESPONSES TO SUBJECTS’ REQUESTS FOR ACCESS TO PERSONAL INFORMATION
4.16. Ensuring Information Security
5. POLICY UPDATE
6. POLICY PLACEMENT
7. CONTACTS
Appendix 1
1. Main Categories of Processed Personal Data Subjects
Appendix 2
1. Terms of Information Disclosure
1.1. Competent Authorities
1.2. Information Processors (Partners)
1. SCOPE OF APPLICATION
1.2. implementation of labor relations;
1.3. conclusion and execution of contractual obligations, as well as in the course of execution of any agreements and contracts related to Personal Data Subjects.
2. The Personal Data Processing Policy (hereinafter referred to as the “Policy”) is an annex to the Privacy Policy and applies to any information that includes personal data of individuals (hereinafter referred to as “Personal Information”).
3. An individual who provided his Personal Information to the Company in the process of obtaining the Service and using any websites (hereinafter referred to as the “Site”), programs, products and/or Internet services (hereinafter referred to as the “Services”) owned by Vimbox, or in the process of establishing a contractual relationship with Vimbox is a User.
4. The main categories of processed Personal Data Subjects are specified in Appendix No.1.
5. The Policy applies to:
1.5.1. Skymath personnel (Skymath personnel means employees working under employment contracts, as well as partners representing Skymath’s interests under civil law contracts) (hereinafter referred to as the “Personnel”);
1.5.2. Skymath shareholders;
1.5.3. Skymath directors;
1.5.4. teachers, students, methodologists, parents of students, potential Users;
1.5.5. Skymath counterparties, if applicable.
6. The requirements of the Policy are taken into account and presented in relation to:
6.1. legal entities included in the Skyeng group (hereinafter referred to as the “Group Companies”);
6.2. other persons, if their participation is necessary in the Personal Information processing (for example, in cases of data transfer in the prescribed manner by Skymath to the Group Companies or other counterparties on the basis of instructions for personal data processing, other agreements and contracts).
7. The list of such legal entities is specified in Appendix No.2 hereto.
- This Policy applies to Skymath LTD (hereinafter referred to as the “Company”, “Skymath”) and describes the procedure for obtaining, processing and protecting any information, including personal data of individuals (hereinafter referred to as the “Personal Data Subject”, “Subject”) in the understanding of applicable law, in connection with:
1.2. implementation of labor relations;
1.3. conclusion and execution of contractual obligations, as well as in the course of execution of any agreements and contracts related to Personal Data Subjects.
2. The Personal Data Processing Policy (hereinafter referred to as the “Policy”) is an annex to the Privacy Policy and applies to any information that includes personal data of individuals (hereinafter referred to as “Personal Information”).
3. An individual who provided his Personal Information to the Company in the process of obtaining the Service and using any websites (hereinafter referred to as the “Site”), programs, products and/or Internet services (hereinafter referred to as the “Services”) owned by Vimbox, or in the process of establishing a contractual relationship with Vimbox is a User.
4. The main categories of processed Personal Data Subjects are specified in Appendix No.1.
5. The Policy applies to:
1.5.1. Skymath personnel (Skymath personnel means employees working under employment contracts, as well as partners representing Skymath’s interests under civil law contracts) (hereinafter referred to as the “Personnel”);
1.5.2. Skymath shareholders;
1.5.3. Skymath directors;
1.5.4. teachers, students, methodologists, parents of students, potential Users;
1.5.5. Skymath counterparties, if applicable.
6. The requirements of the Policy are taken into account and presented in relation to:
6.1. legal entities included in the Skyeng group (hereinafter referred to as the “Group Companies”);
6.2. other persons, if their participation is necessary in the Personal Information processing (for example, in cases of data transfer in the prescribed manner by Skymath to the Group Companies or other counterparties on the basis of instructions for personal data processing, other agreements and contracts).
7. The list of such legal entities is specified in Appendix No.2 hereto.
2. PURPOSES AND LEGAL BASIS FOR PROCESSING
2.1. The purposes of Personal Information processing determine its content and volume.
2.2. Skymath collects and uses Personal Information for the following purposes:
2.3. Legal Basis for Personal Data Processing
2.3.1. The Policy has been developed taking into account the legislative provisions in the field of Personal Information processing, including, but not limited to the US laws on the protection of personal data (of California, Colorado, Virginia and Utah (main and local provisions)), the General Data Protection Regulation, approved by the Regulation (EU) 2016/679 of the European Parliament and the Council dated 27 April 2016 (hereinafter referred to as the “GDPR”), in so far as applicable to the activities of Skymath.
2.1. The purposes of Personal Information processing determine its content and volume.
2.2. Skymath collects and uses Personal Information for the following purposes:
- necessity for our legitimate business interests;
- entering into an agreement with the Subject for the use of the Services or other Services defined by the Company’s Charter;
- ensuring the financial and economic activities of the Company;
- compliance with legal obligations;
- protection of our legal rights and enforcement of judicial and/or administrative orders, in cases where it is necessary.
2.3. Legal Basis for Personal Data Processing
2.3.1. The Policy has been developed taking into account the legislative provisions in the field of Personal Information processing, including, but not limited to the US laws on the protection of personal data (of California, Colorado, Virginia and Utah (main and local provisions)), the General Data Protection Regulation, approved by the Regulation (EU) 2016/679 of the European Parliament and the Council dated 27 April 2016 (hereinafter referred to as the “GDPR”), in so far as applicable to the activities of Skymath.
Purposes of Personal Information Processing
Rights and Obligations of the Company and the Personal Data Subject
2.3.2. Fulfillment of contractual obligations
- provision of paid and free Services to Personal Data Subjects;
- exercise and fulfillment of rights and obligations, including for the purpose of executing an agreement to which the Personal Data Subject is a party or beneficiary or guarantor, as well as for conclusion of an agreement initiated by the Personal Data Subject or an agreement under which the Personal Data Subject will be the beneficiary or guarantor;
- improving the quality of the provided and related Services;
- communication with Personal Data Subjects, if necessary, including for sending notifications, information and requests related to the provision of Services to them, as well as processing applications, orders and other messages received from them.
(1) These notifications include:
- informing about payments,
- marketing and promotional notifications (mailings) about Skymath news, products and Services (messages are sent only if the Subject has given consent to receive them).
(2) The Subject has the right, at any time and free of charge, to refuse to receive notifications (mailings) and other information, using a special procedure for refusing such mailings, if this does not affect the quality of the Services provided.
2.3.3. Fulfillment of legal requirements and obligations
- exercising and fulfilling the functions, powers and duties assigned to a processor (operator);
- enforcement of a judicial act, regulation of another body or official subject to execution in accordance with the enforcement proceedings;
- fulfilling the instructions of other personal data processors/operators.
2.3.4. Ensuring legitimate interests
- carrying out the activities provided for by the Company’s statutory documents;
- creation of new products and offers;
- gathering, processing and presentation of statistical data and other research based on anonymized personal data;
- implementation of recruiting (selection of Personnel), including for the purpose of providing candidates for filling vacant positions with the possibility of being selected for filling the corresponding vacant positions, employment of those who successfully passed the selection for filling the corresponding vacant positions;
- conclusion, execution and termination of civil law contracts;
- exercising and fulfilling the rights and obligations arising from labor relations, including for the purpose of assisting employees in finding employment, obtaining education and promotion in positions, ensuring their personal safety, controlling the quantity and quality of work performed and ensuring the safety of property, paying wages and other payments due to the employee, in accordance with the law or the contract, as well as making tax and social contributions;
- exercising the rights and legitimate interests as a processor or third parties, including protection against copyright infringement, fraud and other unfair conduct;
- making settlements with Personal Data Subjects;
3. PROCEDURE AND CONDITIONS FOR PERSONAL INFORMATION PROCESSING
Personal Information processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not used by automated means such as collection, recording, organisation, structuring, storing, adapting or alteration, retrieval, consultation, use, disclosure by transmission, dissementation or otherwise making available, alignment or combination, restriction, pseudonymisationg or destruction.
3.1. Information Collecting
3.1.1. Collecting of Personal Information is carried out directly from the Personal Data Subject. If the provision of the requested information is mandatory in accordance with legal requirements, the Subject is explained the legal consequences of refusal to provide it.
3.1.2. Obtaining Personal Information from other persons is possible only if there are legal grounds, as well as with the notification of the Subject.
3.1.3. Collecting and processing of Personal Information that does not meet the stated purposes is not allowed.
3.1.4. If the Subject does not want to update Personal Information or refuses to receive informational mailings (for example, marketing ones), he can fill out an opt-out form and send it to the email address dpo@skyeng.eu.
3.2. Obtaining the Subject’s Consent to Personal Information Processing
3.2.1. Personal Information processing is carried out in accordance with the provisions of the current legislation and the agreement with the Subject, after receiving an express and specific consent from him.
3.2.2. Consent can be expressed by the Subject in the form of conclusive actions, for example:
3.2.1.1. by putting marks, filling in the relevant fields in the forms, blanks;
3.2.1.2. by maintaining electronic correspondence that refers to the processing;
3.2.1.3. by accessing the Company’s office territory after familiarization with warning signs and notes;
3.2.1.4. by other actions performed by the Subject, by which one can judge his will.
3.3. Description of Information Processed on the Basis of the Consent
3.3.1. In some cases provided for by legislative, as well as other applicable requirements, consent is drawn up in writing or in standard forms.
3.3.2. In cases of processing Personal Information received not from the Subject directly, but from other persons on the basis of an agreement or instruction for processing, the obligation to obtain the Subject’s consent rests with the person from whom the Personal Information was received.
3.3.3. The Company, if the Subject refuses to provide the necessary and sufficient amount of his Personal Information, will not be able to take the necessary actions to achieve the relevant processing purposes (for example, in the case of an incomplete registration procedure by the User in the Service, the Service under the agreement may not be provided to him, or the applicant’s CV for filling the vacancy will not be considered, etc.).
3.3.4. The Personal Data Subject has the right to withdraw his consent to the processing of his Personal Information by sending a corresponding request to Skymath or to an authorized representative (DPO) at dpo@skyeng.eu.
3.4. Storage Conditions
3.4.1. Skymath, when storing Personal Information, is guided by the Standard Contractual Clauses approved to ensure an adequate level of protection of Personal Information. The list of providers of services for the storage of Personal Information is specified in Appendix No. 2.
3.4.2. The Subject, located in a territory where consent is required for the transfer of his Personal Information to another jurisdiction, provides Skymath with his express and unambiguous consent to such transfer or storage and/or processing of information in other specified jurisdictions.
3.4.3. Skymath, depending on the purposes of Personal Information processing, stores it in the European Economic Area (hereinafter referred to as the EEA).
3.5. Storage Period
3.5.1. Personal information is stored for as long as it is necessary to achieve the purpose for which it was gathered, or to comply with legal requirements or other regulations governing the conditions for its processing.
3.5.2. A longer storage period may be required or permitted by legal requirements, contractual or user agreements.
Personal Information processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not used by automated means such as collection, recording, organisation, structuring, storing, adapting or alteration, retrieval, consultation, use, disclosure by transmission, dissementation or otherwise making available, alignment or combination, restriction, pseudonymisationg or destruction.
3.1. Information Collecting
3.1.1. Collecting of Personal Information is carried out directly from the Personal Data Subject. If the provision of the requested information is mandatory in accordance with legal requirements, the Subject is explained the legal consequences of refusal to provide it.
3.1.2. Obtaining Personal Information from other persons is possible only if there are legal grounds, as well as with the notification of the Subject.
3.1.3. Collecting and processing of Personal Information that does not meet the stated purposes is not allowed.
3.1.4. If the Subject does not want to update Personal Information or refuses to receive informational mailings (for example, marketing ones), he can fill out an opt-out form and send it to the email address dpo@skyeng.eu.
3.2. Obtaining the Subject’s Consent to Personal Information Processing
3.2.1. Personal Information processing is carried out in accordance with the provisions of the current legislation and the agreement with the Subject, after receiving an express and specific consent from him.
3.2.2. Consent can be expressed by the Subject in the form of conclusive actions, for example:
3.2.1.1. by putting marks, filling in the relevant fields in the forms, blanks;
3.2.1.2. by maintaining electronic correspondence that refers to the processing;
3.2.1.3. by accessing the Company’s office territory after familiarization with warning signs and notes;
3.2.1.4. by other actions performed by the Subject, by which one can judge his will.
3.3. Description of Information Processed on the Basis of the Consent
3.3.1. In some cases provided for by legislative, as well as other applicable requirements, consent is drawn up in writing or in standard forms.
3.3.2. In cases of processing Personal Information received not from the Subject directly, but from other persons on the basis of an agreement or instruction for processing, the obligation to obtain the Subject’s consent rests with the person from whom the Personal Information was received.
3.3.3. The Company, if the Subject refuses to provide the necessary and sufficient amount of his Personal Information, will not be able to take the necessary actions to achieve the relevant processing purposes (for example, in the case of an incomplete registration procedure by the User in the Service, the Service under the agreement may not be provided to him, or the applicant’s CV for filling the vacancy will not be considered, etc.).
3.3.4. The Personal Data Subject has the right to withdraw his consent to the processing of his Personal Information by sending a corresponding request to Skymath or to an authorized representative (DPO) at dpo@skyeng.eu.
3.4. Storage Conditions
3.4.1. Skymath, when storing Personal Information, is guided by the Standard Contractual Clauses approved to ensure an adequate level of protection of Personal Information. The list of providers of services for the storage of Personal Information is specified in Appendix No. 2.
3.4.2. The Subject, located in a territory where consent is required for the transfer of his Personal Information to another jurisdiction, provides Skymath with his express and unambiguous consent to such transfer or storage and/or processing of information in other specified jurisdictions.
3.4.3. Skymath, depending on the purposes of Personal Information processing, stores it in the European Economic Area (hereinafter referred to as the EEA).
3.5. Storage Period
3.5.1. Personal information is stored for as long as it is necessary to achieve the purpose for which it was gathered, or to comply with legal requirements or other regulations governing the conditions for its processing.
3.5.2. A longer storage period may be required or permitted by legal requirements, contractual or user agreements.
Category
Storage period
3.5.3. Personal Data Subject
84 months after receiving the Service
3.5.4. Contractor processing Personal Information
one month after the termination of the agreement
3.6. Terms of Destruction or Pseudonymisation
3.6.1. At the end of the period of Personal Information storage, subject to the purposes of its processing, Skymath performs the following actions:
3.6.2. removes redundant Personal Information; or
3.6.3. pseudonymises it so that it is no longer linked to the User or the Personal Data Subject. Such anonymized data may be used for research, statistical purposes, or to improve the quality of our Services. However, Skymath may use it indefinitely without prior notice.
3.6.1. At the end of the period of Personal Information storage, subject to the purposes of its processing, Skymath performs the following actions:
3.6.2. removes redundant Personal Information; or
3.6.3. pseudonymises it so that it is no longer linked to the User or the Personal Data Subject. Such anonymized data may be used for research, statistical purposes, or to improve the quality of our Services. However, Skymath may use it indefinitely without prior notice.
Terms of Destruction or Pseudonymisation
Storage period
Subject
3.6.2. achievement of the purposes of Personal information processing or of the maximum period for its storage
during 30 days
Skymath
(in manual or automated mode)
(in manual or automated mode)
3.6.3. loss of the need to achieve the purposes of Personal Information processing
during 30 days
3.6.4. provision of evidence by the Personal Data Subject or his legal representative that the Personal Information is illegally obtained or is not necessary for the stated purpose of processing
during 7 days
3.6.5. impossibility to ensure the lawfulness of Personal Information processing
during 10 days
3.6.6. withdrawal by the Personal Data Subject of consent to the processing of personal data, if the storage of personal data is no longer required for the purposes of personal data processing
during 30 days
3.6.7. withdrawal by the Personal Data Subject of consent to the use of Personal Information for contacts with potential consumers when promoting goods and Services
during 2 days
3.6.8. expiration of the limitation periods for legal relations within which the Personal Information processing is or was carried out
3.6.9. liquidation (reorganization) of the Company, if the processing was carried out solely in the interests of this entity and there is no legal successor
4. UPDATING, RECTIFICATION , ERASURE AND DESTRUCTION OF DATA, RESPONSES TO SUBJECTS’ REQUESTS FOR ACCESS TO PERSONAL INFORMATION
4.1. Skymath does not verify the Personal Information provided to it, except as stipulated by contractual or user agreements, as well as the terms of use of individual Services, and cannot judge its authenticity and does not have sufficient legal capacity to provide Personal Information.
4.2. The accuracy of Personal Information, its sufficiency and relevance in relation to the purposes of processing, are ensured if it is necessary to protect the legitimate interests of Skymath. In this case, if inaccurate or incomplete Personal Information is found, it may be clarified and updated.
4.1. Skymath does not verify the Personal Information provided to it, except as stipulated by contractual or user agreements, as well as the terms of use of individual Services, and cannot judge its authenticity and does not have sufficient legal capacity to provide Personal Information.
4.2. The accuracy of Personal Information, its sufficiency and relevance in relation to the purposes of processing, are ensured if it is necessary to protect the legitimate interests of Skymath. In this case, if inaccurate or incomplete Personal Information is found, it may be clarified and updated.
Right
What the Subject has the right to do
How to exercise the right
Comment
4.3. to get access to Personal Information
(1) to obtain confirmation of Personal Information processing;
(2) to get access to your Personal Information, as well as information about its processing.
(2) to get access to your Personal Information, as well as information about its processing.
please contact the DPO
The Company may ask you to verify your identity before responding to a request, and in certain circumstances may charge a fee to cover our costs.
The response time is one month after the receipt of the request. If it takes longer to process your request, we will notify you. In any case, we cannot extend the response time by more than two months after the end of the first response month.
The response time is one month after the receipt of the request. If it takes longer to process your request, we will notify you. In any case, we cannot extend the response time by more than two months after the end of the first response month.
4.4. to rectify inaccurate data
to request the rectification of any incomplete or inaccurate data.
please contact the DPO
4.5. to object to processing
to object to the processing of Personal Information if we process it for our own legitimate interests, use it for direct marketing or for statistical purposes.
please contact the DPO
4.6. to require us to make your data portable
in certain circumstances, to require that we provide a copy of Personal Information in a structured, commonly used and machine-readable format.
please contact the DPO
4.7. to erase Personal Information (in whole or in part)
in certain circumstances, to require us to erase Personal Information. For example, if we no longer need it or the Subject withdraws his consent that was the basis for the data processing.
please contact the DPO
4.8. to withdraw consent to data processing
to withdraw your consent to the Personal Information processing.
please contact the DPO
4.9. to restrict processing
to ask to restrict or stop gathering, use, processing and (or) disclosure of Personal Information.
please contact the DPO
4.10. to be informed of the precautions we take when transferring data to a third country or international organization
ask us about these precautions
please contact the DPO
4.11. to file complaints
to complain to a data protection authority about our gathering and use of Personal Information.
please contact your local supervisory authority
4.12. The Subject or his legal representative has the right to send a request to provide/update information about the processing of his Personal Information, or to erase it, and the request should not contain any requirement to provide/change data related to other Subjects. The request from the Subject or his representative must contain (at a minimum):
4.12.1. number of the principal document certifying the identity of the Subject or his legal representative;
4.12.2. information confirming the Subject’s participation in relations with Skymath (agreement number, date of agreement or other information), or information otherwise evidencing the fact of Personal Information processing;
4.12.3. signature of the Personal Data Subject or his legal representative.
4.13. Skymath may refuse the Subject’s request to exercise rights if it is permitted or required in compliance with:
4.13.1. the laws of the United States and other applicable data protection laws (in particular, the GDPR), which we must comply with;
4.13.2. legal requirements that the data operator with whom we cooperate must comply.
4.14. Skymath, in case of refusal of the request, undertakes to provide a response, indicating the reason for such refusal.
4.15. The Subject or his legal representative has the right to file a complaint against our refusal with the supervisory authority.
4.16. Ensuring Information Security
4.16.1. Personal information belongs to the category of confidential information and is subject to protection from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination , as well as from other illegal actions in relation to it.
4.16.2.The Company, when processing Personal Information, takes reasonable and sufficient legal, organizational and technical measures, to maintain a balance between its legitimate interests and the Personal Information security.
4.12.1. number of the principal document certifying the identity of the Subject or his legal representative;
4.12.2. information confirming the Subject’s participation in relations with Skymath (agreement number, date of agreement or other information), or information otherwise evidencing the fact of Personal Information processing;
4.12.3. signature of the Personal Data Subject or his legal representative.
4.13. Skymath may refuse the Subject’s request to exercise rights if it is permitted or required in compliance with:
4.13.1. the laws of the United States and other applicable data protection laws (in particular, the GDPR), which we must comply with;
4.13.2. legal requirements that the data operator with whom we cooperate must comply.
4.14. Skymath, in case of refusal of the request, undertakes to provide a response, indicating the reason for such refusal.
4.15. The Subject or his legal representative has the right to file a complaint against our refusal with the supervisory authority.
4.16. Ensuring Information Security
4.16.1. Personal information belongs to the category of confidential information and is subject to protection from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination , as well as from other illegal actions in relation to it.
4.16.2.The Company, when processing Personal Information, takes reasonable and sufficient legal, organizational and technical measures, to maintain a balance between its legitimate interests and the Personal Information security.
5. POLICY UPDATE
5.1. Skymath has the right to make changes in its sole discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law.
5.2. This Policy is drawn in English and Russian. In the event of discrepancies or any inconsistencies in the semantic content of the terms of this Policy, the text of this Policy in English shall prevail.
5.1. Skymath has the right to make changes in its sole discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law.
5.2. This Policy is drawn in English and Russian. In the event of discrepancies or any inconsistencies in the semantic content of the terms of this Policy, the text of this Policy in English shall prevail.
6. POLICY PLACEMENT
This Policy and the Appendices hereto are provided with unlimited access to all interested parties, including Personal Data Subjects and public authorities exercising control and supervision in the field of Personal Information processing.
This Policy and the Appendices hereto are provided with unlimited access to all interested parties, including Personal Data Subjects and public authorities exercising control and supervision in the field of Personal Information processing.
7. CONTACTS
If you have any questions, comments or requests related to the Policy, please contact our data protection officer at: dpo@skyeng.eu.
If you have any questions, comments or requests related to the Policy, please contact our data protection officer at: dpo@skyeng.eu.
Appendix No.1
1. Main Categories of Processed Personal Data Subjects
1.1. Personal information is collected and processed in order to fulfill contractual obligations, as well as the legitimate interests of the Company.
1.1. Personal information is collected and processed in order to fulfill contractual obligations, as well as the legitimate interests of the Company.
Category
Personal Information
1.2. Skymath shareholders and founders
Information necessary for formalizing labor and civil law relations, in particular, documents containing the name, surname, photo, date of birth and number of the principal identity document.
1.3. Individuals who are or were in labor and civil law relations with Skymath or legal entities within the Skyeng group, as well as persons who intend to enter into such relations (for example, candidates for filling vacancies)
(1) Information necessary for formalizing labor and civil law relations, in particular, but not limited to: documents containing the name, surname, photo, date of birth and number of the principal identity document.
(2) Skymath may take additional steps to verify the Personal Information provided by the Subject.
(3) When formalizing labor and civil law relations, Personal information about the next of kin and/or referral sources may be collected.
(2) Skymath may take additional steps to verify the Personal Information provided by the Subject.
(3) When formalizing labor and civil law relations, Personal information about the next of kin and/or referral sources may be collected.
1.4. Individuals identified in public and other sources that are legally obtained and are used in the provision of the Services by Skymath as data sources
Personal information specified in public and other sources, such as: name, contact information (for example: phone number and/or email), as well as other information necessary for the provision of the Services (for example: address, age, etc.)
1.5. Users, including minors
Copy of an identity document and bank account details (on request); full name; email address; phone number; links to the User’s Google account; accounts on facebook.com, vk.com, ok.ru; accounts in the messengers: WhatsApp, Viber, Telegram, Skype; whether you open our emails and click on the links in them; current location; sex; date of birth; photos, video and audio recordings of classes; level of English (beginner and further); purpose of training; hobbies and interests; sphere of professional activity; information about participation in classes; phone call records. For minors: in addition to the information listed in this paragraph: information about the User’s family members; information about the school where the User is studying; the subject of interest to him (lessons of English or mathematics); additional courses, classes, etc. (for example, tutors)
1.6. Potential User (you register on the Platform, but do not purchase classes)
Full name; sex; email address; phone number; current location; date of birth; level of English; purpose of training; hobbies and interests; sphere of professional activity; whether the User opens our emails and clicks on links in them; information about participation in classes; language; address (city and region/territory); telephone conversation records
1.7. User responsible for running the corporate program in the company
Full name; email address; phone number; current location; telephone conversation records; correspondence
1.8. Teacher
Copy of an identity document; photo; sex; date of birth; photos, video and audio recordings of classes; current location; information about education; exam certificates; CV; telephone conversation records
1.9. Contractor
Copy of an identity document; current location; photo; sex; date of birth; telephone conversation records
1.10. Parents of minor Users
Date of birth; sex; current location; telephone conversation records
1.11. Individuals who contacted Skymath with requests, messages, applications, complaints, suggestions using contact information or feedback collection tools
Information proving the identity of the author of the request, in particular, but not limited to: documents containing the name, surname, date of birth and number of the principal document certifying the identity of the applicant or the identity of his representative.
Skymath may take additional steps to verify the Personal Information provided by the Subject.
Skymath may take additional steps to verify the Personal Information provided by the Subject.
1.12. Individuals participating in interviews, surveys, analytical and marketing research on the subject of Skymath activities
Personal information necessary for interaction, such as: name, contact information (for example: phone number and/or email).
Appendix No.2
1. Terms of Information Disclosure
1.1. Competent Authorities
1.1.1. Upon request, as well as in cases provided for by this Policy or applicable law, and only to the necessary extent based on the purpose of disclosure.
1.1.2. To resolve any conflict or dispute arising in relations between the Subjects and the Company.
1.2. Information Processors (Partners)
1.2.1. Skymath may receive Personal Information from its Partners (hereinafter referred to as the “Partners”) and/or affiliates, including those who are members of the same group with Skymath (hereinafter referred to as “Skyeng”), when they use websites, programs, products or the Internet -services. In such cases, the transfer of Personal Information is carried out in accordance with applicable law, and is made on the basis of special agreements between Skymath and each of the Partners.
1.1. Competent Authorities
1.1.1. Upon request, as well as in cases provided for by this Policy or applicable law, and only to the necessary extent based on the purpose of disclosure.
1.1.2. To resolve any conflict or dispute arising in relations between the Subjects and the Company.
1.2. Information Processors (Partners)
1.2.1. Skymath may receive Personal Information from its Partners (hereinafter referred to as the “Partners”) and/or affiliates, including those who are members of the same group with Skymath (hereinafter referred to as “Skyeng”), when they use websites, programs, products or the Internet -services. In such cases, the transfer of Personal Information is carried out in accordance with applicable law, and is made on the basis of special agreements between Skymath and each of the Partners.
Jurisdiction
Legal entities belonging to the Skyeng group
1.2.2. European Economic Area (EEA)
Vimbox Ltd (Republic of Cyprus)
Langroom Ltd (Republic of Cyprus)
Brandeston Ltd (Republic of Cyprus)
Skyeng Technology S.l.u. (Spain)
Agaton Ltd (Republic of Cyprus)
Sky Language Technology Hong Kong Ltd
Langroom Ltd (Republic of Cyprus)
Brandeston Ltd (Republic of Cyprus)
Skyeng Technology S.l.u. (Spain)
Agaton Ltd (Republic of Cyprus)
Sky Language Technology Hong Kong Ltd
1.2.3. Russian Federation
Sky Service Rus LLC
Educational Technologies LLC
ANPE SVE SKYENGSKYENG LLC
Language Innovations LLC
Educational Technologies LLC
ANPE SVE SKYENGSKYENG LLC
Language Innovations LLC
1.2.4. Legal entities belonging to the Skyeng group may act as persons processing Personal Information on the basis of contracts and other agreements. Such cases include, for example, the following:
1.2.4.1. granting rights to use software products to customers;
1.2.4.2. provision of Services related to data processing to customers;
1.2.4.3. implementation of joint processing with third parties within the framework of a partnership.
1.2.4.1. granting rights to use software products to customers;
1.2.4.2. provision of Services related to data processing to customers;
1.2.4.3. implementation of joint processing with third parties within the framework of a partnership.