Privacy policy

This policy sets out how personal data is processed and protected on the site solhorse.ru and is drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 on personal data.

Personal data operator: КСК «Соловьиная Роща», address: МКАД, 97-й км, внешняя сторона, Национальный парк Лосиный Остров, лесничество. Referred to below as the Operator.

The policy is published openly as required by part 2 of article 18.1 of that law and covers all personal data the Operator receives through the site.

1. Key terms

• Personal data: any information relating to a directly or indirectly identified individual.
• Data subject: the individual the personal data relates to, that is a visitor of the site, a client of the services, a user of the account area.
• Processing: any action with personal data, including collection, recording, storage, correction, use, transfer and deletion.
• Site: the set of pages at solhorse.ru.

2. Whose data and what data is processed

The Operator processes data of visitors of the site, clients of the services and users of the account area.

When a lesson request is placed, the following is processed: first name, last name, phone number, email address if given, the text of the comment to the request, the chosen service, the date and time of the lesson, the number of participants.

When an account is created, the following is processed in addition: login, email address, encrypted password, profile photo if uploaded.

When the contact form is used, the following is processed: name, phone number, email address if given, the text of the message.

When the site is visited, the following is processed automatically: IP address, information about the browser and the device, the date and time of the request, the address of the requested page, the address of the referring page, cookie data.

The Operator does not process special categories of personal data or biometric personal data. Information about health that affects admission to a lesson is given verbally to the administrator or the coach and is not stored in the information systems of the site.

3. Purposes of processing and legal grounds

• Receiving and confirming requests, providing services, settlements. Ground: clause 5 of part 1 of article 6 of law No. 152-FZ, processing is necessary to perform a contract to which the data subject is a party.
• Running the account area and giving access to the history of bookings. Ground: consent of the data subject, clause 1 of part 1 of article 6.
• Replying to enquiries sent through the contact form and messengers. Ground: consent of the data subject.
• Sending messages related to the performance of the contract: confirmation of a booking, a reminder about a lesson, information about payment. Ground: performance of the contract.
• Sending informational and advertising messages. Ground: separate consent of the data subject, article 18 of the Federal Law on advertising.
• Keeping the site working and secure and protecting it from automated requests. Ground: legitimate interest of the Operator and the requirements of the Federal Law on information, information technology and the protection of information.
• Meeting duties imposed by law, including keeping documents about settlements. Ground: clause 2 of part 1 of article 6.

The Operator does not process personal data for purposes incompatible with those listed above and processes only the data needed for the stated purpose.

4. Consent to processing

Consent is given by the data subject by ticking the relevant box in a form on the site. Consent to the processing of personal data is given separately from any other consent and is not combined with it in one box.

A refusal to give data that is not necessary for providing a service does not lead to a refusal to provide that service.

Consent may be withdrawn at any time in the way described in section 9 of this policy.

5. Terms and means of processing, place of storage

Processing is carried out both with and without automation. Recording, storage and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation, as required by part 5 of article 18 of law No. 152-FZ.

Data is kept no longer than the purpose of processing requires:

• request data and information about the service provided are kept for the term of the contract and for three years after it is performed, which matches the general limitation period;
• account data is kept until the account is deleted by the data subject or consent is withdrawn;
• enquiries sent through the contact form are kept for one year from the day of the enquiry;
• documents about settlements are kept for the periods set by the legislation on accounting and taxes;
• server log records are kept for no longer than twelve months.

Once the purpose of processing is met, the data is destroyed within thirty days, unless the law provides otherwise.

6. Cookies and statistics

The site uses cookies. Technically necessary cookies keep the account area working, remember the chosen language and protect forms from automated requests, and without them the site will not work.

Analytics cookies, where used, serve to measure traffic in an anonymised form.

A user may block the saving of cookies in the browser settings or delete the files already saved. Some features of the site will then become unavailable.

7. Transfer of data to third parties

The Operator does not sell personal data and does not transfer it for purposes not set out in this policy.

Data may be transferred to parties engaged to provide services, to the extent needed for them to perform their functions, and under a contract that obliges them to keep confidentiality and to follow law No. 152-FZ:

• the hosting provider whose equipment the site is placed on;
• the service that protects forms from automated requests;
• the email service through which letters are sent;
• the payment system operator, if online payment is connected, to the extent needed to carry out the payment;
• the fiscal data operator, to the extent needed to issue a cash receipt.

Data may be passed to state authorities on the grounds and in the manner set by law.

The site carries a map widget and a reviews widget of third party services. When they load, the third party service may receive information about the fact of the request, including the IP address. The processing of that information is governed by the policy of the service in question.

8. Cross border transfer

The Operator does not carry out cross border transfer of personal data. Should such a transfer become necessary, it will be carried out no earlier than after notifying the authorised body for the protection of the rights of personal data subjects and in compliance with article 12 of law No. 152-FZ.

9. Rights of the data subject

The data subject has the right to:

• obtain confirmation that processing takes place and information about it to the extent set by part 7 of article 14 of law No. 152-FZ;
• require that data be corrected, blocked or destroyed if it is incomplete, out of date, inaccurate, obtained unlawfully or not necessary for the stated purpose;
• withdraw consent to processing;
• object to receiving advertising messages;
• appeal against the actions of the Operator to the authorised body for the protection of the rights of personal data subjects or to a court.

A request is sent to info@solhorse.ru or by post to МКАД, 97-й км, внешняя сторона, Национальный парк Лосиный Остров, лесничество. The request must contain information that identifies the person making it and information confirming their relationship with the Operator.

A reply to a request is given within ten working days from the day it is received. This period may be extended by no more than five working days, with notice of the reasons for the extension.

When consent is withdrawn, processing stops and the data is destroyed within thirty days, except where the law obliges the Operator to keep it further.

An account can be deleted by the user in its settings or on request to info@solhorse.ru.

10. Protection measures

The Operator takes the legal, organisational and technical measures set out in article 19 of law No. 152-FZ, including the following:

• appoints a person responsible for organising the processing of personal data;
• limits access to the data to those employees who need it for their work;
• uses a secure connection when data travels between the browser and the site;
• stores passwords as an irreversible transformation, passwords are never stored in the open;
• keeps a record of access to the data and makes regular backups;
• assesses the harm that may be caused to data subjects and matches the measures taken to it.

11. Actions in case of an incident

If an unlawful or accidental transfer of personal data is discovered that breaches the rights of data subjects, the Operator notifies the authorised body for the protection of the rights of personal data subjects within twenty four hours of the fact itself and within seventy two hours of the results of the internal investigation, as required by part 3.1 of article 21 of law No. 152-FZ.

12. Processing of data of minors

The Operator does not deliberately collect data of persons under eighteen. A request for a lesson for a child is placed by a legal representative in their own name, and such a request processes the data of the representative together with the name and the age of the child where that is needed to choose a suitable lesson.

13. Changes to the policy

The Operator may change this policy. A new version is published on this page and takes effect from the moment it is published. The date of the version is shown under the heading.

14. Contacts

• Name: КСК «Соловьиная Роща»
• Address: МКАД, 97-й км, внешняя сторона, Национальный парк Лосиный Остров, лесничество
• Email for personal data enquiries: info@solhorse.ru
• Phone: +7 (929) 575-56-87