Privacy Policy

This Privacy Policy (hereinafter referred to as the “Policy”) represents the rules for the use of the received personal information of the User by the limited liability company “SayAnyway”.

1. Terms and Definitions
   1. The following terms and definitions are used in this Policy and in the relations of the Parties arising thereof or associated therewith:
      • Administration of the Platform (Administration) means “SayAnyway” LLC, OGRN (Primary State Registration Number): 1215000064047, INN: 5074070033, Address: 142110, Moscow region, city district Podolsk, Podolsk city, Mashtakova str., 12, room/floor 312/3.
      • User means a person who has entered into the Contract with the Administration in its own or third party's interest in accordance with the applicable law and the Contract.
      • Contract means a contract for the use of the Platform on a fee-free basis (User Agreement, thereinafter, the Agreement), License Agreement for Products use, and/or another agreement with the Administration proposed for conclusion and/or concluded by the User in pursuance of any offer posted on the Platform.
      • Website means the automated information system accessible at the Internet address (including subdomains): https://www.sayanyway.com/.
      • Platform means the integrated software and hardware system “Sayanyway” for the organizing and holding of remote meetings (video conferences) between the Platform Users for the purposes of the development of communication skills in English, including the Website, the Products and other computer programs and/or databases, implementing the Platform functionalities.
      • Products means computer programs and databases that implement particular functionalities of the Platform, the right to use which is provided under the conditions of a separate license contract with the Administration.
   2. This Policy uses the terms and definitions specified in the Agreement, as well as in other Contracts concluded with the User, unless otherwise is set forth in this Policy or follows from its essence. In other circumstances, the interpretation of the term used in the Policy is given in accordance with the applicable law of the Russian Federation, customary business practices or scientific doctrine.
2. General
   1. This Policy constitutes an integral part of the documents referring to it, including the User Agreement, the Public Offer for the license contract, and the Contracts concluded on the basis of the said documents.
   2. By using the Platform through the Website, registering/logging into the Platform, sending a request to the Administration through the feedback form, placing an order for the Products, and/or entering into the Contract, you, acting with free will and in your own interest, give your written consent to the following ways of processing Personal Information: recording, systematization, storage, rectification (update, change), extraction, use, transfer (provision, access) to third parties, including cross-border data transfer to foreign jurisdictions, anonymization, blocking, deleting, destruction for the purposes and in the manner prescribed by this Policy, using automation tools or without using such tools at the Administration's discretion.
   3. This Policy, including the interpretation of its provisions and the procedure for its adoption, execution, amendment and termination, is subject to the legislation of the Russian Federation.
3. Personal Information
   1. The Personal Information in this Policy means the following:
      1. The information that the User independently provides about himself when registering or authorizing in the Platform, as well as in the process of other use of the Platform, including the User's personal data.
      2. Data that is transmitted automatically, depending on the User's software settings, in an anonymized form.
   2. The Administration has the right to establish requirements for the composition of the User's Personal Information, which must be given for the use of he Platform and/or entry into the Contract by specifying such information. If certain information is not marked by the Administration as obligatory information, its provision or disclosure shall be carried out by the User at his/her own discretion.
   3. When the Users are registered in the “Moderator” status, the following data must be specified: name, electronic mail address, country, time zone, password, photo. In order to fill out a profile in the Platform, the following may be indicated: surname, patronymic name, currency of the service fee from among the available currencies, gender, subscriber phone number, date of birth, prices for individual and group meeting, bank details, the list of subject categories within which the Moderator holds meetings, as well as the information about yourself in free form.

      When the Users are registered in the “Speeker” status, the following data must be specified: name, electronic mail address, country, time zone, subscriber's phone number, password, photo. In order to fill out a profile in the Platform, the following data may be specified: surname, patronymic name, currency of the service fee, gender, level of English knowledge, date of birth, as well as the information about yourself in free form.

      When registering/authorizing the User in the Platform using the authentication services of social networks, such as Vkontakte, etc., the User provides its with Personal Information to the Administration using these authentication services. The composition of the provided information depends on the used service and may include, in addition to the information required for registration/authorization in the Platform, the information included in the User profile on the Website, as well as the User identifier in such a social network.

      When returning the funds paid under the Contract, the User may be obliged to provide additional information (passport data) in his/her own handwritten application in accordance with the requirements of applicable law.

      When the User sends a message to the Administration through the contact form in the Platform, the following must be indicated: name, electronic mail address.

   4. Public information. Depending on the Platform operational characteristics and/or the User settings, unlimited range of persons (other Users) may have access to certain part of the User's profile data. The user gives his/her informed consent to the access of unlimited range of persons to such information. Part of the User's profile data comes into the public domain on the basis of the profile settings from the moment it is posted on the Platform by the User alone or at his/her request.
   5. The Administration does not carry out the validation of the input Personal Information and whether the User has the necessary consent to process it in accordance with this Policy, assuming that the User acts in good faith, prudently and makes all necessary efforts to maintain the current status of such information and obtain all the necessary consents of the personal data subjects.
   6. The User recognizes, accepts and agrees that the Administration uses the software of third parties in the Platform, as a result of which such parties can receive and transmit anonymized data in an automatic mode.

      The specified software of third parties includes systems for collection and processing of analytical data:

      • Google Analytics implementing the data collection and processing in accordance with the privacy policy posted and/or available at the Internet address: https://policies.google.com/privacy;
      • Yandex.Metrica implementing the data collection and processing in accordance with the privacy policy posted and/or available at the Internet address: https://yandex.ru/legal/confidential/;

      The above mentioned list is not limiting, the Administration may use other similar systems and terminate the use of the systems included in the list.

      Data being collected using the software of third parties may include:

      • data about the User's device (model, manufacturer, available memory capacity, location (country, city), operation system data (type, version, screen resolution) and others;
      • query data (time, transition source, IP address);
      • cookie* file data;
      • other anonymized data about the User actions on the Website.

      The composition, as well as the conditions for the collection and use of anonymized data by the copyright holders of the specified software are determined directly by such copyright holders and are regulated by documents that are posted and/or available on theirs Internet sites.

      By accepting this Policy, as well as by setting certain settings in his/her software, the User agrees to the conditions of data collection and use by the copyright holders of the above mentioned software.

      *Cookie file is a small text file written in the user's device and containing information about the user's actions in the Internet. Some of these files can help determine the location, others can remember user settings. The parameters for working with cookie files shall be configured by the User in his/her browser. It is, however, not recommended to deny the acceptance of all cookies: in this case, the User will not be able to use some of the Platform functionalities.

      Anonymized data is not combined with the information about the User specified in clause 3.1.1 and is not used to identify the Users.

   7. The Administration shall not be liable for the procedure of using the User's Personal Information by other Users and third parties with whom the User interacts within the framework of using the Platform.
4. Purposes of Personal Information processing
   1. The Administration carries out processing, including the collection and storage of such Personal Information that is necessary for the conclusion and performance of the Contracts with the User.
   2. The Administration has the right to use Personal Information for the following purposes:
      1. The entry into the Agreements for the use of the Platform, as well as the entry into other Contracts involving the use of the Platform.

         The conclusion of the Contracts shall be carried out in the remote mode through the exchange of electronic documents which are signed with a simple electronic signature. In this event, the role of the key of User's simple electronic signature is performed by the pair of password – electronic mail address. This is why such data are requested during the registration.

      2. User identification as part of the fulfillment of obligations under the Agreement and other Contracts concluded with the User.

         The User's account is related to the User's password and electronic mail address.

         When providing information and technical support, the User is identified by name, surname, electronic mail address and subscriber's phone number.

      3. The performance of the obligations under the signed Agreement and other Contracts, including the User's access to the Platform, the rights to the Products usage and technical support, the use of the functions of the Platform and Products by the User.

         In order to implement the relevant functionalities of the Platform, the Administration stores, systemizes and displays the User profiles in the Platform, including the data dispalyed as publicly available information (clause 3.4 of the Policy).

         The name, surname and electronic mail address are used to provide to the User the rights to use the Products and technical support services.

      4. Security and privacy of the User's Personal Information.

         In order to identify suspicious activities, the Platform collects information about the IP address and browser used by the User.

      5. The refund of the balance of the paid money in the case of termination of the paid-service Contracts concluded with the User.

         To return the funds paid under the Contract, the User may be obliged to provide additional information in accordance with the applicable law.

      6. Notification within the information service and/or service quality increase under the signed Contracts, including the involvement of third parties.

         In order to provide notices, the User's electronic mail address and subscriber phone number are used.

      7. The conduct of marketing, statistical and other researches based on anonymized data for the purposes of the Platform quality enhancement.

         Data from the analytical data collection systems specified in clause 3.6 of the Policy, are collected and analyzed in an anonymized form to find out the interests and preferences of the Users.

      8. The targeting of advertising and/or information materials with the use of anonymized data from the analytical data collection systems specified in clause 3.6 of the Policy.
5. Personal Information security requirements
   1. The Administration shall carry out the storage of the Personal Information and ensure its protection from unauthorized access and distribution in accordance with internal rules and regulations.
   2. The confidentiality of the User's Personal Information is properly maintained, except for the Public Information (clause 3.4 of this Policy), and the other circumstances when the Platform technology or the User's settings of the software provide for the exchange of information with other Users or third parties.
   3. To enhance the Platform quality, the Administration has the right to store log files about actions performed by the User while using the Platform, as well as in connection with the conclusion and performance of the Contracts by the User.
6. Information Transmission
   1. The Administration has the right to transmit Personal Information to third parties in the following cases:
      • The User has expressed his/her consent to such actions, including the User's applying the settings of the software used, which do not restrict the provision of certain information;
      • The transmission of data is necessary as part of the User's usage of the Platform's functionalities, including for the conclusion and performance of the Contracts in respect to the Platform use; specifically, the Platform allows the exchange of data between the Users when organizing and holding a remote meeting using the Platform. The User's data can be also transmitted to Robokassa (https://www.robokassa.ru/) and PayPal (https://www.paypal.com/) payment systems.
      • In the circumstances related to the involvement of third parties, providers of the services to the Administration. The Personal Information is transmitted to such service providers for the sole purpose of providing services to the Administration. Specifically, electronic mail addresses can be transmitted to the JivoChat technical support chat service (https://www.jivo.ru), as well as to the electronic distribution services used by the Administration.
      • Due to the use of the software of third parties in the Platform for collecting and processing User data. Specifically, the Administration may use the software of third parties in accordance with clause 3.6 of this Policy in order to collect and process anonymized data;
      • Due to the transfer of the Platform by Administration for possession, use or to the ownership of a third party, or the assignment of rights under contracts concluded with the User in favor of a third party;
      • On the request of a court or other authorized government agency subject to the procedure established in accordance with the law;
      • To protect the rights and legitimate interests of the Administration in connection with the violation of the Contracts concluded with the User.
7. Change and deletion of the Personal Information
   1. The User has the right at any time to independently edit or delete the Personal Information his/her User's Account, provided by the User during the registration or authorization.
   2. In the event of termination of the Agreement and/or Contract, the User has the right to delete the User's Account by contacting the support service at the electronic mail address specified in this Policy.
8. Changes to the Privacy Policy
   1. This Policy can be changed or terminated by the Administration unilaterally without a prior notice to the User. The new version of the Policy becomes effective on the date of its posting on the Website, unless otherwise provided by the new version of the Policy.
   2. The current version of the Policy is located on the Website at the address https://www.sayanyway.com/privacy-policy.
9. Details of the Administration:

   “SayAnyway” LLC

   Legal/postal address: 142110,

   Moscow region, city district Podolsk, Podolsk city,

   Mashtakova str., 12, room/floor 312/3.

   OGRN (Primary State Registration Number): 1215000064047

   INN: 5074070033, KPP 507401001

   Acct. at «Bank Otkritie Financial Corporation»

   (Public Joint-Stock Company) 40702810408500016289

   Corr. acct.: 30101810845250000999

   with the Main Branch of the Central Bank of the

   Russian Federation for the Central Federal District, Moscow

   BIC: 044525999

   Email: info@sayanyway.com

    

   The current version of the Policy dated July 15, 2021