Personal Data Processing Policy
1. Operator and scope
1.1. The operator is Индивидуальный предприниматель Калашникова Ольга Валерьевна, INN 502106187405, OGRNIP 325774600591127, address: г. Москва, ул. Вертолётчиков, д. 4, к. 7, кв. 54. Personal data inquiries are accepted by e-mail at info@omnistudy.ru and by phone at +7 968 865-99-85.
1.2. This Policy applies to the dovuz-mirea.omnistudy.ru website, the online course, the personal account, and related forms. The Service is intended for persons over 18 years of age. Reviewing this Policy does not substitute for separate consent.
1.3. Personal data means not any technical information in and of itself, but information relating to a directly or indirectly identified user. For example, a local checklist mark without an identifier does not describe a specific person; the same mark, once synchronized with an account, becomes part of that user's personal data about their progress.
1.4. The operator processes data of the following categories of data subjects: site visitors who have not created an account; registered users of the Service; purchasers who have paid for access to the Course Materials; authors of reviews who have consented to their distribution; persons who have submitted an inquiry, an error report, or another request through the contacts indicated. The operator does not intentionally collect data of minors, legally incapable persons, or special categories of personal data.
2. What data is processed
2.1. Account data: email; the password as an irreversible hash; nickname, avatar, full name, and Telegram handle where provided; registration and login dates; the flag and date of email confirmation; the date of the 18+ confirmation; access status and term.
2.1.1. Email is the primary account identifier: it is used for login, password recovery, and delivery of legally significant notices. The Telegram handle is provided optionally, serves only as a backup communication channel for access and payment matters, is not used for login, and does not replace email. The field may be left empty at registration, and may be filled in or cleared in the profile at any time; declining to provide it does not restrict use of the Service. The Telegram handle is not displayed to other users and is not transferred to the rating or reviews.
2.2. Usage data associated with the account: selected plan and checklist items, module progress, activity by date, achievements, user-created task variants and their content.
2.3. Legal and protective records: the versions, time, source, and SHA-256 of accepted consents and of the offer; one-time password-reset links and the time of their issuance and use; one-time email confirmation codes and the time of their issuance, expiration, and use; IP and User-Agent — only where account protection is separately permitted.
2.4. User content: nickname, avatar, rating, and review text; full name and email for executing consent to its distribution; a feedback message, page URL, task number, and screenshot. You should not provide special categories of data or information about third parties.
2.5. Payment data: the amount, date, and time of the payment; its identifier in the payment service and status; the request idempotency key; refund information; the email transmitted to the payment service for the cash receipt. Payment is made on the payment service's page: the bank card number, its expiration date, and the card verification code do not reach the site — the operator does not receive, transmit, or store them.
3. Purposes and legal grounds
3.1. The account, access to materials, saving of progress, and performance of the offer are provided on the basis of separate consent, the contract, and statutory requirements to the extent applicable. The license under the offer is granted for an unlimited term, so the contractual relationship continues even after access is opened: account data is processed for as long as the account exists and is not terminated at the moment of payment.
3.2. An error report is processed on the basis of the contract and the very fact of your inquiry — separate consent is not required for this and is not requested. Publication of a review to an unlimited circle of persons is based on separate consent to distribution. The consents are not merged with the offer.
3.3. Proprietary visit analytics, Yandex.Metrica, and the storage of IP for account protection are enabled only after selecting "Accept all". Selecting "Only necessary" does not disable the core functionality of the Service.
3.3.1. Acceptance of payment and opening of access are carried out on the basis of the contract concluded by acceptance of the offer. Issuance and delivery of the cash receipt, accounting and tax records, and the refund of paid amounts upon withdrawal from the contract are carried out on the basis of obligations imposed on the operator by law — consent is not required for this, and withdrawal of consent does not terminate them.
3.4. Advertising and marketing mailings are not conducted. Only service messages necessary for the operation of the account and performance of the contract are sent to the email provided: password-recovery links, access notices, replies to inquiries, and cash receipts. Email is not transferred to third parties for advertising. If mailings are introduced, separate consent will be requested for them — silence or the mere fact of registration is not deemed consent to advertising.
4. Operations, retention periods, and deletion
4.1. The operator carries out the collection, recording, systematization, accumulation, storage, refinement, extraction, use, necessary provision to processors, blocking, deletion, and destruction of data by automated and non-automated means. Legally significant decisions are not made solely by automated means.
4.2. Account data is stored until the account is deleted or the purposes are achieved, unless the law requires otherwise. The user may delete the account on their own. The consent history is stored for the period necessary to confirm the lawfulness of processing.
4.2.1. Deletion of the account does not delete information about completed payments: the law obliges the operator to store accounting and tax records regardless of the purchaser's will. After the account is deleted, such records are detached from it and stored without email or other data allowing the user to be identified — the amount, date, payment identifier, and refund information remain.
4.3. Analytics and IP are deleted after 90 days. Used and expired password-reset links — no later than 7 days. The email confirmation code is valid for 30 minutes and is invalidated upon entry or upon issuance of a new one; the record of an issued code is deleted together with the account. Security events are stored for up to 365 days. Processed inquiries and their screenshots — up to 365 days, while any inquiry, regardless of the status of its review, is stored no later than 3 years. Rejected reviews are deleted after 90 days, unless they are needed to address a claim or to comply with a statutory requirement.
4.4. Backup copies are stored for a limited period and protected from ordinary access; deleted data finally disappears from them upon scheduled rotation. Accounting and tax records are stored for the periods provided by law separately from the site database.
5. Processors and localization
5.1. The initial recording, systematization, accumulation, storage, refinement, and extraction of data of citizens of the Russian Federation are carried out in databases located within the territory of the Russian Federation.
5.1.1. The operator does not carry out any cross-border transfer of personal data. Data is not transferred to the territory of foreign states, is not hosted on foreign servers, and is not provided to foreign legal entities or individuals. All processors engaged by the operator are Russian persons processing data within the territory of the Russian Federation. Should such a transfer ever become necessary, the operator will first submit a notice to Roskomnadzor pursuant to Article 12 of Federal Law No. 152-FZ of July 27, 2006, and will amend this Policy before the transfer begins.
5.1.2. Reservation to clause 5.1.1: correspondence in the Telegram messenger (clause 5.4) is conducted on the infrastructure of a third-party service that the operator neither chooses nor controls. Such correspondence begins only at the user's own initiative — when they voluntarily provided a handle or wrote first — is conducted in the scope the user themselves determines, and does not constitute a transfer by the operator of a body of personal data abroad: databases, exports, and learning progress are not sent to the messenger. A user who does not wish to use a foreign service always has an equivalent alternative available — contacting by email.
5.2. Infrastructure is provided by OOO "TIMEWEB.CLOUD" (INN 7810945525), whose servers are located in a data center in Moscow. The provider may process data to the extent necessary for the operation of the infrastructure. Development and technical support of the Service are carried out by a processor engaged by the operator on its instructions; access to data is granted to that processor to the minimum necessary extent and solely for diagnostics. Before connecting a new email, analytics, or payment processor, the operator refines the scope of the transfer, the contractual terms, and this Policy.
5.2.1. Visit statistics are maintained with the help of Yandex.Metrica — a service of OOO "YANDEX" (Russian Federation). With respect to the collection and processing of statistics on the operator's instructions, Yandex acts as a processor acting on its behalf. At the same time, Yandex processes part of the visitors' data as an independent operator — for its own purposes and on the basis of its own terms of use of the service, rather than on the operator's instructions. The operator does not manage such processing and is not responsible for it; its terms are published on the Yandex website. The counter loads and sets its cookies only after selecting "Accept all"; when "Only necessary" is selected, the Metrica script is not added to the page. Metrica has access to visit information: the page address, time, referral source, device and browser type, approximate region, and the IP address processed by Yandex. Email, full name, Telegram handle, and learning progress are not transferred to Metrica. You may opt out via the "Only necessary" button or the "Cookie" link at the bottom of the site.
5.2.2. Webvisor is enabled as part of Metrica. It records on-page behavior: scrolling, cursor movements, clicks, window resizing, and the sequence of pages viewed within a single visit. A scroll map and a click map are built from these recordings — they show how far people read down the page and where they click. Recording is governed by the same "Accept all" selection and ceases upon its withdrawal.
5.2.3. Form content is not captured in the recording. Before recording starts, all forms and input fields are marked with two service classes: the first hides the field's content in the recording, the second disables keystroke recording within it. Email, password, inquiry text, and review text are not transferred to Webvisor and are not reproduced in the recordings. The password, moreover, does not leave the browser in cleartext under any analytics settings.
5.2.4. A recording of an authenticated user's behavior relates to a specific person and constitutes their personal data. That is precisely why it is conducted only on the basis of separate consent, falls within the "visit statistics" purpose, and is not used for making decisions about access, price, or blocking. Opting out of Webvisor is possible at any time via the "Only necessary" button — the rest of the analytics cannot be disabled separately from it; both purposes are enabled and disabled by a single selection.
5.3. The operator does not sell data and does not transfer it for others' advertising. Transfer is possible to a processor acting on the operator's instructions, to the payment service to the extent necessary to accept payment and issue the cash receipt, or upon a lawful request of an authorized authority.
5.4. Correspondence in Telegram is conducted only with those who have themselves provided a handle or written first, and solely on matters of access, payment, and support. Telegram is a third-party service operating under its own rules and outside the operator's control: messages are processed on its infrastructure, so you should not transmit passwords, payment details, or information you do not wish to disclose to a third party in the correspondence. User databases, exports, and learning progress are not transferred to the messenger. Contact by email always remains an available alternative, and the Telegram handle can be deleted in the profile.
5.5. Payment is accepted by the YooKassa service (OOO NKO "YuMoney"). By clicking "Buy", the user proceeds to the payment service's page and enters card details there — this form is not hosted on the operator's site. The operator transmits to the payment service the amount, the purpose of the payment, its own internal order identifier, and the purchaser's email for the cash receipt; email is transmitted solely for the receipt and is not used by the payment service for advertising purposes on the operator's behalf. In return, the operator receives the payment identifier and status.
5.5.1. When accepting a payment, the payment service acts as an independent personal data operator: it processes the payer's data under its own contract with the payer and in fulfillment of the requirements of legislation on the national payment system and on countering the legalization of proceeds obtained by criminal means. The operator does not manage such processing and is not responsible for it; its terms are published on the payment service's website. With respect to the generation of the cash receipt, the payment service acts on the operator's instructions — the obligation to issue the receipt rests with the operator as the seller.
5.5.2. The cash receipt is, by operation of law, transmitted to the fiscal data operator and to the Federal Tax Service. The composition of the receipt is defined by Federal Law No. 54-FZ of May 22, 2003; from the user, it includes only the email to which the receipt is sent. This transfer cannot be declined — it is an obligation of the operator, not a matter of its discretion.
6. Cookies, IP, and local data
6.1. Necessary cookies maintain the login session and CSRF protection. They are not disabled via the banner, because without them the forms and the personal account cannot operate securely.
6.2. Selecting "Accept all" permits three things: proprietary analytics — the page, time, authentication flag, and a truncated SHA-256 fingerprint of the IP and User-Agent; loading of the Yandex.Metrica counter with Webvisor and its cookies (including _ym_uid, _ym_d, and _ym_visorc, whose retention period is determined by Yandex); and recording of the authenticated user's IP and User-Agent for account protection. Before this selection, the application creates no such records, and the Metrica script does not load. "Only necessary" disables all three purposes. The selection can be changed via the "Cookie" link at the bottom of the site.
6.3. localStorage on the device may store the theme, the navigation view, the selected plan, the state of checklists, and the identifier of the current variant. These local values do not contain email or full name. Part of the learning progress is separately synchronized with the account and is treated as personal data under clause 2.2.
7. Rating, reviews, and inquiries
7.1. The nickname, avatar, and progress are shown to other authenticated users in the rating only after a separate optional checkmark. Email and full name are not displayed. The checkmark can be unchecked in the profile — the user immediately disappears from the rating.
7.2. A review is not published automatically. It requires separate consent to distribution, acceptance of the publication rules, and manual moderation. Only the nickname, avatar, rating, text, and date are public; the full name and email from the consent remain confidential.
7.3. The author may delete the review and withdraw consent in the profile. Feedback screenshots are not published and are accessible only to authorized personnel through administrative authorization.
8. User rights
8.1. The user has the right to obtain information about the processing, to demand refinement, restriction, blocking, or deletion of data, to withdraw consent, and to appeal the operator's actions to Roskomnadzor or a court. A request is sent to info@omnistudy.ru.
8.2. Withdrawal of consent does not affect the lawfulness of prior processing and does not terminate processing permitted by law without consent. If the account cannot be maintained without the necessary data, its use is terminated.
8.3. Processing based on consent is terminated within no more than 30 days from the day the withdrawal is received. After termination, the data is destroyed unless the operator retains another lawful ground to store it — in which case only the scope expressly required by law is retained, and only for the period established by it.
9. Protection and changes
9.1. Access segregation, password hashing, CSRF protection, restricted access to attachments, limits on automated guessing, logging of logins and administrative actions, and deletion by established deadlines are applied. Personnel access is limited to business necessity.
9.2. The current revision is published here. When the purposes or composition of processing change in a way that requires new consent, the user will see a separate form; consent is not created retroactively.