Politique de confidentialité

Version dated 4 September 2026

This Personal Data Processing Policy (the "Policy") sets out the procedure for processing and protecting the personal data of users of lidenz.ru and online.lidenz.ru.

The personal data controller is:

Private Educational Institution of Supplementary Education Courses "Lingua Consult (Language Consultant)"

• Russian legal name: ЧОУ ДО Курсы «Лингва Консалт (Языковой Консультант)»

• Primary State Registration Number (OGRN): 1037843038078

• Taxpayer Identification Number (INN): 7825669155

• Registered address: Premises 12N, Building A, 3 Zhukovskogo Street, St Petersburg, 191014, Russian Federation

• Email: online-support@lidenz.ru

The Controller processes personal data in accordance with Federal Law No. 152-FZ of 27 July 2006, "On Personal Data", and other applicable laws and regulations of the Russian Federation.

This Policy applies to personal data obtained through lidenz.ru and online.lidenz.ru, enquiry and course registration forms, user accounts, and subsequent interactions with users in connection with the provision of educational and related services.

Depending on the service used, the Controller may process:

• first name and surname;

• email address;

• telephone number;

• date of birth;

• country of residence and time zone;

• information about the selected language, course, level and study format;

• information about the timetable, teacher and lessons completed;

• information about lesson packages purchased and used;

• information about orders and payment status;

• the content of enquiries, applications and correspondence with the Controller;

• user account identifiers;

• technical data, including IP address, browser and device type, date and time of access, cookies and information about use of the website.

The Controller does not intentionally collect special categories of personal data concerning health, political opinions, religious or philosophical beliefs or intimate life, or biometric personal data, unless otherwise specifically required or permitted by the laws of the Russian Federation.

3.1. Processing Applications and Enquiries

To respond to a user's request, provide information about courses and services, assess language proficiency, and select a programme, teacher and timetable.

3.2. Registration and Use of online.lidenz.ru

To create and administer a user account, authenticate the user, restore access and provide the functionality of the personal account.

3.3. Entering Into and Performing a Contract

To organise and conduct lessons, maintain the timetable, record lessons purchased and used, facilitate interaction with students and teachers, and provide learning materials and other ordered services.

3.4. Payment for Services

To process orders, record payments and refunds, and comply with accounting, tax and other legal requirements of the Russian Federation.

The Controller does not store users' full bank card details.

3.5. User Support

To process questions, enquiries, complaints, claims and technical support requests.

3.6. Security

To protect user accounts and information systems and prevent unauthorised access, abuse and fraud.

3.7. Website Analysis and Improvement

To analyse website performance, traffic and use of individual functions, resolve technical errors, and improve services.

3.8. Information and Advertising Messages

News, information about courses, special offers and other advertising messages are sent only where the user has given separate consent to receive such messages.

The user may opt out of advertising messages at any time.

Personal data is processed:

• with the consent of the data subject, where such consent is required by law;

• in order to take steps at the request of the data subject before entering into a contract;

• in order to perform a contract to which the data subject is a party or beneficiary;

• in order to comply with obligations imposed on the Controller by the laws of the Russian Federation;

• in other cases provided for by the laws of the Russian Federation.

Consent to personal data processing is obtained separately from other documents, agreements and consents accepted by the user.

Withdrawal of consent does not prevent the Controller from continuing to process personal data where another lawful ground for such processing applies.

The Controller processes personal data using automated means and, where necessary, without using automated means.

The Controller's principal information systems and databases used to operate lidenz.ru and online.lidenz.ru are located in the Russian Federation.

The Controller uses amoCRM to manage customer relationships. Data within the infrastructure used by the Controller is hosted in the Russian Federation.

When personal data of citizens of the Russian Federation is collected through the Internet, the recording, systematisation, accumulation, storage, updating and retrieval of such data are carried out using databases located in the Russian Federation.

Access to personal data is granted only to employees, teachers, contractors and other authorised persons to the extent necessary for the performance of their respective duties.

The Controller does not disseminate personal data or disclose it to third parties without a lawful basis.

Personal data may be transferred or otherwise made available to organisations and persons involved in the provision of the Controller's services, including:

• hosting and technical support providers;

• the CRM provider;

• payment service providers;

• providers of email, communications and other necessary IT infrastructure;

• the Controller's teachers and employees, to the extent necessary to organise studies;

• public authorities, in cases provided for by law.

Only the amount of data necessary for the relevant purpose is transferred or made available.

Some users of online.lidenz.ru may be offered the option of paying for services using foreign payment methods.

When choosing such a payment method, the user leaves online.lidenz.ru and is redirected to a separate foreign payment page.

Before being redirected, the user is informed that the payment is accepted by a foreign legal entity and that the processing of personal data on the foreign payment page is governed by the documents of the relevant operator.

Bank card details are entered by the user directly on the foreign payment page and are not transmitted to the Controller of online.lidenz.ru.

Personal data contained in the user's online.lidenz.ru account is not transferred automatically to the foreign payment page.

After payment, the Controller may receive the information necessary to identify the payment, confirm its status and provide the user with the paid services.

If a payment method used in the future involves the transfer of personal data by the Controller to a foreign person, such transfer will be carried out in accordance with the requirements of the laws of the Russian Federation governing cross-border transfers of personal data.

The websites use cookies and similar technologies to:

• operate the websites and personal accounts;

• authenticate users;

• save user preferences;

• ensure security;

• analyse website performance and traffic.

The websites may use the Yandex Metrica web analytics service.

Users may restrict or delete cookies through their browser settings.

Disabling cookies necessary for the operation of the website may make certain functions unavailable.

Personal data is processed for no longer than is necessary for the purposes of processing or as required by the laws of the Russian Federation.

Personal data required to provide services and perform a contract may be retained for the duration of the contractual relationship and after it ends for the period necessary to comply with legal, accounting and tax requirements, consider potential claims and protect the Controller's lawful rights.

Data processed solely on the basis of the data subject's consent is processed until:

• the purpose of processing has been achieved;

• the consent expires;

• the data subject withdraws the consent, unless another lawful ground for continued processing applies.

Contact details used solely for advertising communications are processed until the user withdraws consent to receive such communications.

Once the purposes of processing have been achieved and there are no other lawful grounds for retention, personal data is destroyed or anonymised.

The Controller takes the necessary legal, organisational and technical measures to protect personal data against:

• unlawful or accidental access;

• destruction;

• alteration;

• blocking;

• copying;

• disclosure;

• dissemination;

• other unlawful acts.

Access to the Controller's information systems is restricted and granted only to authorised persons.

The Controller conducts internal monitoring of compliance with the requirements of the laws of the Russian Federation governing personal data and takes measures to identify and remedy possible violations in a timely manner.

The data subject has the right to:

• obtain information about the processing of their personal data;

• learn the purposes and legal grounds for processing;

• obtain information about the categories of personal data being processed;

• request correction of incomplete, inaccurate or outdated data;

• request blocking or destruction of data in cases provided for by law;

• withdraw previously given consent;

• request that processing cease in cases provided for by the laws of the Russian Federation;

• lodge a complaint with Roskomnadzor;

• protect their rights through the courts.

To exercise these rights, the user may send a request to: online-support@lidenz.ru

The request must contain information enabling the Controller to verify the identity of the applicant and establish that the relevant personal data is being processed.

The Controller may amend this Policy if the laws of the Russian Federation, the information systems used, the methods of processing or the services provided change.

The current version of the Policy is permanently available to the public on:

• lidenz.ru

• online.lidenz.ru

The date of the latest version is stated at the beginning of this document.