Privacy policy

This privacy policy («policy») will help you understand how the Academic mobility center («us», «we», «our») uses and protects the data you provide to us when you visit and use http://mobilitypass.ru and https://academic-mobility.ru websites («website», «service»).

We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

1.1 We are committed to safeguarding the privacy of Academic mobility center website, Mobility Passport website and its service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of the Academic mobility center website, Mobility Passport website and its service users; in other words, where we determine the purposes and means of the collect, process and collect, process and store of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of Academic mobility center website, Mobility Passport website, and its services, we will ask you to consent to our use of cookies when you first visit our website. Cookies are necessary to ensure the functioning and smooth operation of the website. See details in section 8.

1.4 Our website incorporates privacy controls which affect how we will collect, process and store your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

You can access the privacy controls via writing us to info@academic-mobility.ru.

2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may collect, process and store;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may collect, process and store personal data; and
(d) the legal bases of the collect, process and store (more in Section 14).

2.2 We may collect, process and store data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and Tilda data systems. This usage data may be collected, processed and stored, processed and stored for the purposes of analysing the use of the website and services. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may collect, process and store your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be collected, processed and stored, process and stored for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may collect, process and store your information included in your personal profile on our website ("profile data"). The profile data may include your name and surname, address, telephone number, email, address, profile pictures and photo, gender, date of birth, relationship status, emergency contact name and surname, his/her contact phone number, interests and hobbies, educational details and employment details, as well as your personal documents details, such as numbers, issuing institutions, date of issue, and date of expiration. Moreover, we recognise profile data all information that contain details of your travel documents and visas, your language proficiency, special mobility requirements that you may have (disabilities, allergies, required assistance, dietary recommendations), information about your medical insurance, details of your fewer opportunity status, information about all forms of mobility programs you participated or been enrolled in (education exchange. short-term, internships, volunteer programs, online education). We also include information about all learning outcomes, activities, YouthPass numbers and Europass documents in the profile data that we may collect, process and store

The profile data may be collected, processed and stored, process andstored for the purposes of enabling and monitoring your use of our website and services. It is also used to create the opened data base for employers, educational institutions, and other entities which may have an access to your profile data (published by you). The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5 We may collect, process and store your personal data that are provided in the course of the use of our services ("service data»). The service data may include your name and surname, address, telephone number, email, address, profile pictures and photo, gender, date of birth, relationship status, emergency contact name and surname, his/her contact phone number, interests and hobbies, educational details and employment details, as well as your personal documents details, such as numbers, issuing institutions, date of issue, and date of expiration. Moreover, we recognise profile data all information that contain details of your travel documents and visas, your language proficiency, special mobility requirements that you may have (disabilities, allergies, required assistance, dietary recommendations), information about your medical insurance, details of your fewer opportunity status, information about all forms of mobility programs you participated or been enrolled in (education exchange. short-term, internships, volunteer programs, online education). We also include information about all learning outcomes, activities, YouthPass numbers and Europass documents in the profile data that we may collect, process and store.The service data may be collected, processed and stored, process and stored for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6 We may collect, process and store information that you post for publication on our website or through our services ("publication data"). The publication data may be collected, processed and stored, process and stored for the purposes of enabling such publication and administering our website and services. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the proper administration of our website and business.

2.7 We may collect, process and store information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be collected, processed and stored, process and stored for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this collect, process and collect, process and store is consent.

2.8 We may collect, process and store information relating to our customer relationships, including customer contact information ("customer relationship data»). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you. The customer relationship data may be collected, processed and stored, process and stored for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this collect, process and collect, process and store is consent.

2.9 We may collect, process and store information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website] ("transaction data»). The transaction data may include your contact details, your card details and the transaction details.The source of the transaction data is you and our payment services provider. The transaction data may be collected, processed and stored, process and stored for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this collect, process and collect, process and store is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.10 We may collect, process and store information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be collected, processed and stored, process and stored for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this collect, process and collect, process and store is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.11 We may collect, process and store information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be collected, processed and stored, process and stored for the purposes of communicating with you and record-keeping. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.12 We may collect, process and store any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.13 We may collect, process and store any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this collect, process and collect, process and store is our legitimate interests, namely the proper protection of our business against risks.

2.14 In addition to the specific purposes for which we may collect, process and store your personal data set out in this Section 2, we may also collect, process and store any of your personal data where such collect, process and collect, process and store is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://academic-mobility.ru. We also may disclose your personal data to any entities which accesses http://mobilitypass.ru open data base.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of collect, process and collect, process and store your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://kassa.yandex.ru.

3.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data. Your personal data could be disclosed with your consent.

3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we collect, process and store for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:
(a) Identification data such as your name, date of birth, number and picture of passport, your occupation status and other details detained will be retained for a minimum period of 2 years following the date of obtaining it by us, and for a maximum period of 10 years following the date of obtaining it by us.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based on Russian Federal law No374 and No375.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.6. You can withdraw your consent to the collection, processing and / or storage of your personal data, as well as demand their deletion or change at any time by notifying us by e-mail: info@academic-mobility.ru or through the contact form of our website.

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you about significant changes to this policy by email or through the private messaging system on our website.

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law (Section 14) are :
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict collect, process and collect, process and store;
(e) the right to object to collect, process and collect, process and store;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we collect, process and store your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the collect, process and collect, process and store, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the collect, process and collect, process and store, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise collect, process and stored; you withdraw consent to consent-based collect, process and collect, process and store; you object to the collect, process and collect, process and store under certain rules of applicable data protection law; the collect, process and collect, process and store is for direct marketing purposes; and the personal data have been unlawfully collect, process and stored. However, there are exclusions of the right to erasure. The general exclusions include where collect, process and collect, process and store is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 In some circumstances you have the right to restrict the collect, process and collect, process and store of your personal data. Those circumstances are: you contest the accuracy of the personal data; collect, process and collect, process and store is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our collect, process and collect, process and store, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to collect, process and collect, process and store, pending the verification of that objection. Where collect, process and collect, process and store has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise collect, process and store it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 You have the right to object to our collect, process and collect, process and store of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the collect, process and collect, process and store is that the collect, process and collect, process and store is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to collect, process and store the personal information unless we can demonstrate compelling legitimate grounds for the collect, process and collect, process and store which override your interests, rights and freedoms, or the collect, process and collect, process and store is for the establishment, exercise or defence of legal claims.

7.8 You have the right to object to our collect, process and collect, process and store of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to collect, process and store your personal data for this purpose.

7.9 You have the right to object to our collect, process and collect, process and store of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the collect, process and collect, process and store is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our collect, process and collect, process and store of your personal data is:
(a) consent; or
(b) that the collect, process and collect, process and store is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such collect, process and collect, process and store is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our collect, process and collect, process and store of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12 To the extent that the legal basis for our collect, process and collect, process and store of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of collect, process and collect, process and store before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us.

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
.

9.1 We use cookies for the following purposes:
(a) authentication — we use cookies to identify you when you visit our website and as you navigate our website
(b) status — we use cookies to help us to determine if you are logged into our website
(c) personalisation — we use cookies to store information about your preferences and to personalise the website for you
(d) security — we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
(e) advertising — we use cookies to help us to display advertisements that will be relevant to you
(f) analysis — we use cookies to help us to analyse the use and performance of our website and services, and
(g) cookie consent — we use cookies to store your preferences in relation to the use of cookies more generally

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://policies.google.com/privacy.

10.3 We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising
Initiative's multi-cookie opt-out mechanism at: https://optout.networkadvertising.org/
However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-di... (Firefox);
(c) https://www.opera.com/help/tutorials/security/cook... (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/win... (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-mic... (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12.1 This website is owned and operated by the Academic mobility center.

12.2 We are registered in the Russian Federation under registration number 1177700020420, and our registered office is at Moscow, Frunzenskaya nab. 52, pom. III., komn. 3, Russian Federation, 119270.

12.3 Our principal place of business is at Moscow, Frunzenskaya nab. 52, pom. III., komn. 3, Russian Federation, 119270.

12.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.

Our data protection officer's contact details are:

Roskomnadzor Russia, Moscow, Kitaygorodsky pr-d 7, str. 2
+7 (495) 987-67-70

14.1. This privacy policy applies to the following laws and regulations:

• https://ec.europa.eu/info/law/law-topic/data-protection/reform/rules-business-and-organisations_en (GDPR)
• http://curia.europa.eu/juris/document/document.jsf?text=&docid=218462&pageIndex=0&doclang=en&mode=req&dir=&occ=first&part=1&cid=1438413 (Decision of the European Court of Justice)
• http://curia.europa.eu/juris/document/document.jsf?text=&docid=218105&pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&cid=931095 (Decision of the European Court of Justice)
• https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002L0058:en:HTML (ePrivacy directive)
• https://data.consilium.europa.eu/doc/document/ST-12633-2019-INIT/en/pdf (ePrivacy regulation)
• http://www.legislation.gov.uk/ukpga/2018/12/contents/enacted (Legislation act, the UK)
• https://www.admin.ch/opc/en/classified-compilation/19920153/index.html (Federal law, Switzerland)
• https://www.refworld.org/pdfid/4d2ee2b72.pdf (Federal law, Bosnia and Herzegovina)
• https://www.right2info.org/resources/publications/laws-1/laws_belarus-foi-law (Federal law, Belarus)
• https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=22575 (California state law, USA)
• https://www.isipp.com/resources/full-text-of-the-california-consumer-privacy-act-of-2018-ccpa/ California state law, USA)
• https://www.leg.state.nv.us/App/NELIS/REL/80th2019/Bill/6365/Text (Bill of Nevada Senate, USA)
• https://mainelegislature.org/legis/bills/getPDF.asp?paper=SP0275&item=1&snum=129&mkt_tok=eyJpIjoiTWpJelpqSTNORGhtTVRneSIsInQiOiJlc0ZlYWhNZVZ3UTA3clwvaUVCVFZkY0tBQ3FpWDU1U1A4QU9PWFVKSjZWdE03VTkxdnpxUE16VjI3U25EMHUxcm8yOVhqWHZGQzlNSWxoY01cL3g3cnF1TEJEXC9rOXplcXNYKzE2MDVqUmwzeTF0OWVJcjFEdlZHSDkrYzJZdzdpKyJ9 (Legislative law of state Maine, USA)
• https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/02_05_d_15/ ((Federal law, Canada)
• https://www.oaic.gov.au/individuals/privacy-fact-sheets/general/privacy-fact-sheet-17-australian-privacy-principles ((Federal law, Australia)
• http://www.legislation.govt.nz/act/public/1993/0028/latest/whole.html ((Federal law, New Zeland)
• https://www.amchamchina.org/uploads/media/default/...:-china%27s-cybersecurity-law--(translation-added)&utm_medium=email (Federal law, China)
• https://www.insideprivacy.com/wp-content/uploads/sites/6/2019/06/Draft-Regulation-on-the-Protection-of-Childrens-Personal-Information-Online_bilingual.pdf (Federal law, China)
• http://meity.gov.in/content/view-it-act-2000 ( Federal law, India)
• https://www.wipo.int/edocs/lexdocs/laws/en/in/in098en.pdf ((Federal law, India)
• https://www.ppc.go.jp/files/pdf/Act_on_the_Protection_of_Personal_Information.pdf (Federal law, Japan)
• http://koreanlii.or.kr/w/images/0/0e/KoreanDPAct2011.pdf (Federal law, Korea)
• http://www.pdp.gov.my/images/LAWS_OF_MALAYSIA_PDPA.pdf ((Federal law, Malaysia)
• https://www.bu.edu/bucflp-fig/files/2012/01/Law-No.-11-Concerning-Electronic-Information-and-Transactions.pdf (Federal law, Indonesia)
• https://sso.agc.gov.sg/Act/PDPA2012 (Федеральный закон Сингапура)
• https://www.elegislation.gov.hk/hk/cap486!en-zh-Hant-HK.pdf?FROMCAPINDEX=Y (Federal law, Hong Kong)
• https://law.moj.gov.tw/Eng/LawClass/LawAll.aspx?PCode=I0050021 (Federal law, Taiwan)
• https://globalcompliancenews.com/vietnam-law-cybersecurity-20180702/ (Federal law, Vietnam)
• https://privacy.gov.ph/data-privacy-act/ (Federal law, Philippines)
• https://privacy.gov.ph/wp-content/uploads/2016/07/IRR-Version-072716.pdf (Federal law, Philippines)
• https://content.next.westlaw.com/4-520-1732?transitionType=Default&contextData=(sc.Default)&__lrTS=20180825154027643&firstPage=true&bhcp=1 (Federal law, Brazil)
• https://www.pnm.adv.br/wp-content/uploads/2018/08/Brazilian-General-Data-Protection-Law.pdf (Federal law, Brazil)
• http://unpan1.un.org/intradoc/groups/public/documents/un-dpadm/unpan044147.pdf (Federal law, Argentina)
• http://media.mofo.com/files/uploads/Documents/FederalDataProtectionLaw2010.pdf (Federal law, Mexico)
• http://unpan1.un.org/intradoc/groups/public/documents/UN-DPADM/UNPAN041914.pdf (Federal law, Israel)
• http://www.consultant.ru/document/cons_doc_LAW_61801/ (Federal law, Russia)
• https://www.kvkk.gov.tr/SharedFolderServer/CMSFiles/aea97a33-089b-4e7d-85cb-694adb57bed3.pdf (Federal law, Turkey)
• http://www.justice.gov.za/inforeg/docs/InfoRegSA-POPIA-act2013-004.pdf (Federal law, South Africa)
• http://www.legalaffairs.gov.bh/AdvancedSearchDetails.aspx?id=146182#.XZskJkYzbIU (Laws of Gulf countries)