Revised on 01 October 2021
In this Privacy Statement (Personal data protection policy), terms and definitions are used as they are described in the Licence Agreement with the End User.
1. The Privacy Statement (hereinafter referred to as “Statement”) defines the procedure of collection, processing and storage of personal data of Users described in items 3 and 4 of the Statement (hereinafter referred to as “Personal data”), as well as any other use of Personal data on the web site at https://puzzle-english.com and/or in the mobile version of the web site https://puzzle-english.com for iOS, Android and Huawei, which represents a computer programme intended for installation on a mobile device (tablet, mobile phone, smartphone, communicator, or other device that enables intended functional use of the Mobile app) so as to provide the User with access to the Web Site.
2. The User can provide his/her Personal data to the Website owner (Licensor) only voluntarily. In this case the Website owner (Licensor) shall be guided by the Policy for collection, processing and storage of Personal data of the User.
3. The Website owner (Licensor) requests and the User provides the following Personal data:
– last name, first name, patronymic name (if applicable), contact phone number and e-mail of the User, which are all required to create an account and enable further communication;
– information on the User’s account: login, password, account settings on the Website, which are all required to maintain Website security, correct technical issues concerning Website functioning, as well as to analyse data and maintain records;
– conversation history in messengers (e.g. WhatsApp), audio and video recordings of classes (Sessions), in which the User participates, which is needed for monitoring of the process of rendering of Services and for improvement of their quality.
4. The Website owner (Licensor) obtains the following Personal data of the User from third parties:
– the User’s data from his/her profile on Google, in Facebook and VKontakte social networks, Website cookies – this is required for filling out of the User’s profile on the Website, as well as for updating and analysis of the data already available, and collection of information on services rendered by the Licensor on the Website.
5. All Personal data of Users are collected and processed by the Licensor for the purpose of rendering or receiving the Services and improvement of their quality.
6. All Personal data of Users are stored in the Licensor’s databases on the Licensor’s servers located in the Russian Federation.
7. By signing up (by creating an account) on the Website, the User agrees that his/her Personal data will be processed and expresses his/her full consent with the terms of this Statement and Licence Agreement.
8. In the event of disagreement with conditions of this Statement the use of the Website must be immediately discontinued by the User.
9. By accepting terms and conditions of the Licence Agreement and Statement, the User agrees with automated processing of the provided Personal Data for the purpose of conclusion of the agreement between the User and Licensor, as well as for its consequent fulfillment. Automated processing of Personal Data shall be understood as any action (operation) or set of actions (operations) performed with Personal Data using processing automation means or without using such means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, utilisation, transfer (distribution, provision, accessing), anonymisation, blocking, deletion, and erasure of Personal Data.
10. In cases foreseen by the Federal Law, processing of Personal Data is performed only based on a written consent of the User.
11. The Licensor undertakes all necessary measures for protection of Personal Data of the User from unauthorised access, modification, disclosure or erasure.
12. The User agrees that the Licensor transfers the User’s Personal Data, which he/she has not made publicly available and which are necessary for the fulfillment of the Agreement and Terms of Use, to third parties.
13. The Licensor provides access to Personal Data of the User only to duly authorised employees and contractors of the Licensor, who need this information to ensure rendering of Services to the User, Website functioning, or communication with the User.
14. Disclosure of Personal Data provided to the Licensor by the Website User (Licensee) shall only be possible by court order, by request of law enforcement agencies, as well as in other cases if required by the law.
15. The Licensor does not perform validity checks of Personal Data provided by the User, except for the cases when such a validity check is necessary for the purpose of fulfillment of Licensor’s liabilities to the User.
16. In cases foreseen by the Website functionality, the User, at his/her own discretion, determines the extent of availability of his/her Personal Data to other Internet users.
17. The User acknowledges and agrees that in the event of allocation of his/her Personal Data using the Website in a way, which allows those data to be obtained by Internet users, the Personal Data are deemed publicly available. The User also acknowledges that his/her Personal Data are deemed publicly available in cases when confidentiality requirements do not apply to them in accordance with laws of the Russian Federation.
18. The User agrees that his/her cookies are recorded on the Website, particularly but not exclusively by third parties, for the purpose of statistics, analysis of User behaviour on the Website and optimisation of advertisements. Cookies are a small fragment of data which is sent by a web server and stored on the User’s computer, and which is sent by a web client or web browser to the web server within an HTTP request each time when a corresponding web page is being opened.
19. Personal Data of the User are kept for 365 calendar days since the date the User last visited the Website.
20. Personal data are subject to automatic erasure upon User-initiated deletion of his/her personal profile on the Website. The profile is deleted by the User using the function “Delete profile” available at https://puzzle-english.com/user#settings, or is deleted based on the personal request of the User submitted to the Customer Support Service at support@puzzle-english.com. The User can also request deletion of his/her Personal Data and/or other data related to his/her personal profile (such as task completion history, language test results, etc.), by contacting the Customer Support Service at: support@puzzle-english.com. The User can modify Personal Data using the function for settings changing, which is available at https://puzzle-english.com/user#settings, or by contacting the Customer Support Service at support@puzzle-english.com.
21. The User can withdraw his/her consent for Personal Data processing at any point of time by submitting a corresponding notification in any format to the Licensor’s e-mail at support@puzzle-english.com. The Licensor shall process such a notification within maximum thirty (30) calendar days from the date of receipt of the User’s letter.
22. The Licensor reserves the right to make alterations to this Statement. In the event of making such alterations, the date of the latest alteration is indicated in the current revision of the document. The new revision of the Statement becomes effective from the moment of its publication, unless provided otherwise by the new revision of the Statement. The current edition is always available at: https://puzzle-english.com/privacy-policy-ru.
