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ALGORITMIKA GROUP PRIVACY POLICY
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This is the privacy policy of Algoritmika Group which includes:
  • Algoritmika, LLC, a company having its address in Moscow, Russia. Algoritmika LLC is a legal entity incorporated in accordance with the laws of the Russian Federation under the primary state registration number 5167746505273 ("Algoritmika Russia"); and

  • Ruffell Holdings Ltd, a company having its address in Limassol, Cyprus. Ruffell Holdings Ltd is a legal entity incorporated in accordance with the laws of the Cyprus under the registration number ΗΕ 397064 ("Algoritmika Cyprus", together with Algoritmika Russia - "Algoritmika Group", "we", "us" or "our").
By using our platform, websites, services, products, software ("Services"), you understand and agree to the collection and use of your and your child's information in accordance with this privacy policy. Our privacy policy applies to all visitors, users, clients, and others natural persons who access to our Services ("you" or "your") provided we execute the function of data controller (joint data controller) with respect to your and/or your child's personal data.

This policy applies to the extent it does not contradict service agreement signed between our sub-franchisee and respective data subject. In case of any discrepancies, privacy and confidentiality clauses of that service agreement prevail over the provisions of this privacy policy.

PLEASE READ THIS POLICY ATTENTIVELY.

1. WHO ARE WE

IN SHORT: We are a group of companies developing an interactive platform for children whose parents are interested that their children receive after-school programming classes. EU customers get access to its functionality through our sub-franchisees. We obtain and process personal data regarding our sub-franchisees' clients as well as limited personal data of representatives of our potential sub-franchisee in accordance with the General Data Protection Regulation.

We, at Algoritmika Group, have developed an interactive platform for children whose parents are interested that their children receive after-school programming classes ("Platform"). We do not provide services to EU customers directly (with exception for Algoritmika Cyprus providing services to Cypriot customers). By means of Algoritmika Cyprus franchise program (which by itself is a franchisee of Algoritmika Russia dully authorized to enter into sub-franchise agreements) we instead attract trusted EU providers to become our sub-franchisees. We grant them access to the functionality of Platform, administer the Platform, provide sub-franchisees with all information that they need to start and operate business, support them in the course of their business' launch, check the quality of their services, and do other things that franchisers typically do with respect to their franchise network

We therefore mainly obtain and process two kinds of personal data of our sub-franchisee' clients: (1) when they provide our sub-franchisee with their personal data as well as with the personal data of their children or (2) when we receive additional data directly from our sub-franchisee' client in certain limited cases. We also process limited personal data of representatives (agents, employees or otherwise) of our potential sub-franchisees.

While we also process some personal data of representatives (agents, employees or otherwise) of our existing sub-franchisees, such processing is out of scope of this policy. We request our sub-franchisees to obtain the consent of respective data subjects for such processing and rely on it. If for whatever reason they did not receive your consent for us to process your personal data, please contact us immediately using contact details provided below.

This privacy policy explains how we collect, use, share and protect information in relation to our Services. Our Services, other than the Platform and contact forms of our websites, are not designed to target EU data subjects specifically. Even if any personal data processing of EU data subjects takes place, this happens inadvertently or incidentally.

We process personal data of EU data subjects in accordance with the General Data Protection Regulation (the "GDPR"), the GDPR-based legislation and the other applicable privacy legislation.

2. HOW TO CONTACT US

IN SHORT: You can find our contacts below. Our representative in EU is sub-franchisee with whom you entered into service agreement. If in doubt, contact us at dpo@algoritmika.org

You may contact Algoritmika Russia using the following contact details: dpo@algoritmika.org

You may contact Algoritmika Cyprus using the following contact details: ruffel.holdings@com

Pursuant to GDPR, Algoritmika Russia must appoint our representative in EU. Even though you can always contact Algoritmika Cyprus for any matters concerning Algoritmika Russia, we have also appointed Algoritmika Russia' sub-franchisee in respective EU member with whom Algoritmika Cyprus has entered into sub-franchisee agreement to be Algoritmika Russia representative in EU. In most cases this the company with whom you entered into service agreement to provide after-school programming classes to your child.

If in doubt as to our EU representative in your given case, please contact us at dpo@algoritmika.org

3. 1. WHAT INFORMATION DO WE COLLECT

IN SHORT: We collect personal data that you provide to us such as your and your child's name, age, country, contact information. We get some personal data when you and (or) your child use the services of our sub-franchisee to the extent they enter this information into our platform. We also collect some information directly from you in a limited number of cases. Finally, we collect some personal data automatically.

(a) What data do we collect

Data you disclose to us

When you contact with us with the purpose to discuss our after-school programming classes for children, we get access to the following personal data:

  • your name
  • your location within EU (country and address)
  • your contact phone number
  • your contact e-mail address
  • your age
When you contact with one of our EU sub-franchisees, we get access to your and/or your child's personal data that they put into our Platform with respect to you and/or your child:

  • your name
  • your location within EU (country and address)
  • your contact phone number
  • your contact e-mail address
  • your date of birth and your age
  • your passport details
  • your legal basis for exercising parental rights with respect to your child
  • your child's name
  • your child's gender
  • your child's age
  • your child's contact phone number
  • your child's contact e-mail address
  • other information with respect to you and/or your child that our sub-franchisees put into our Platform

Data we get when and (or) after you use the services provides to you by our sub-franchisee

When you enter into agreement with one of our EU sub-franchisees, we additionally get access to the following data that they put into our Platform with respect to you and/or your child:

  • your child's individual progress with the services that our sub-franchisee provides to you
  • your and your child's preferred sub-franchisee
  • pages you or your child viewed
  • the features you or your child use
  • error reports
  • links you or your child click on to leave or interact with our Platform
  • other applications your child use on his or her device
  • other information with respect to you and/or your child that our sub-franchisees put into our Platform

After you enter into agreement with one of our EU sub-franchisees, we may get in contact with you directly in a limited number of cases and receive the following data with respect to you and/or your child:

  • your and your child's feedback with respect to Platform
  • your and your child's feedback with respect to services that our sub-franchisee provides or have provided to you, including your impression as to the quality of these services
  • your and your child's feedback as to our sub-franchisee compliance with our standards and policies
Data we get when you contact us on behalf of our potential sub-franchisee

If you are a representative (agent, employee or otherwise) of our potential sub-franchisee and you approach us with the purpose to discuss entering into franchise agreement, Algoritmika Cyprus gets the following personal data with respect to you:

  • your name
  • your location within EU (country)
  • your position with our potential sub-franchisee
  • your contact phone number
  • your contact e-mail address
  • your age (if you are above 16 years old)

(a) What data do we collect automatically

We also collect the following data:

  • Internet Protocol (IP) address when you or your child log into the Services and respective log information and error messages
  • browser type that you or your child use when you access our websites
  • type of device (personal computer/notebook, mobile device), respective unique device identifiers, such as device Media Access Control (MAC) address, precise location data, device motion data, or both, if you or your child grant permission to do so in your device settings
  • time of access to our websites

(b) What data do we receive from cookies

We will also receive information from cookies. We have special policy for cookies and for your convenience we placed it on our web-site algorithmicschool.com

(c) What data we must have

We noted above that we administer the Platform and therefore we get access to all information that our sub-franchisee inputs in it. It is impossible to restrict us from getting access to this information. You should not enter into agreement with our sub-franchisee if you don't want that we get access to your and your child's data.

You however may opt-out that we contact you directly albeit we don't recommend doing that because in this case we may not guarantee that you receive services satisfying all standards that we impose on our sub-franchisees.


4. HOW DO WE USE YOUR INFORMATION

IN SHORT: We use your and/or your child's personal data for a variety of business purposes. Below we explain how and for which purpose we use that information.

If you are a person exercising parental rights with respect to a child – we indicate the specific legal basis of processing grounds we rely on next to each purpose listed below:

Identify you and your child. We will use information to get understanding of a person who entered into agreement with our sub-franchisee and of a person who uses the Platform and consumes our sub-franchisee' services. We use this information based on your consent.

Contact with you and your child. We will use information to communicate with you and your child; to request feedback regarding our Platform, our sub-franchisee' services and our sub-franchisee' compliance with our standards and policies; to answer your requests; to provide you with any support and assistance that you or your child may need if for whatever reason you cannot or don't want to contact our sub-franchisee directly. We need this information for our legitimate business interests and based on your consent.

Provide you and your child with the personalized service. We will use this information to ensure that you receive from our sub-franchisee the services that you have accessed or requested or the services that are the most suitable for your child; to personalize your and his or her experience; to make statistical analysis (including with the use of special web instruments, such as Yandex.Metrics, Google.Analytics); to provide technical support to you and your child if for whatever reason you, he or she cannot or don't want to contact our sub-franchisee directly. We need this information for our legitimate business interests and based on your consent.

Keep the results of your child's individual progress with our sub-franchisee' services. We will use information to ensure that our sub-franchisee provides you and your child with regular update of the progress your child has with its services; to ensure that our sub-franchisee takes steps to identify areas for his or her further improvement; to ensure that our sub-franchisee provides you with a tailored feedback; to make statistical analysis (including with the use of special web instruments, such as Yandex.Metrics, Google.Analytics); to ensure that our sub-franchisee proposes you the services that are the most suitable for your child and other customers. We need this information for our legitimate business interests and based on your consent.

Improve our Platform and the quality of our sub-franchisee' services. We will use information to improve, test, and monitor the effectiveness of our Platform and improve the quality of the services that our sub-franchisees provide to their customers; to develop new services and features that our sub-franchisees may propose to you and other clients; to make statistical analysis (including with the use of special web instruments, such as Yandex.Metrics, Google.Analytics); to monitor metrics such as total number of visitors, traffic, and demographic patterns; to protect and improve the security and safety of our Platform, you, your child and other customers, Algoritmika Group, our sub-franchisees, other business partners, and others. We need this information for our legitimate business interests and based on your consent.

Other business reasons. We will use this information to enforce our terms, conditions and policies, to respond to legal requests and prevent harm. We may also use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our marketing efforts. We need this information for our legitimate business interests and based on your consent.

If you are a representative of our potential sub-franchisee - we indicate the specific legal basis of processing grounds Algoritmika Cyprus relies on next to each purpose listed below:

Identify and contact you. We will use information to get understanding of a person who entered into contact with Algoritmika Cyprus; to communicate with you; to request feedback regarding the Platform, our compliance with our standards and policies; to answer your requests; to provide you with any support and assistance that you may need; to maintain our business relations with respective sub-franchisee. We need this information for our legitimate business interests and based on your consent.

Other business reasons. We will use this information to enforce our terms, conditions and policies, to respond to legal requests and prevent harm. We may also use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our marketing efforts. We need this information for our legitimate business interests and based on your consent.

Where our legitimate business interests are mentioned this includes, depending on purpose, building client-tailored Platform, ensure sub-franchisees' compliance with our standards, develop our sub-franchise network, extend the list of client offerings, increase of the overall information security of the modern society, extend the spectrum of professions' choice available for children.

We receive you consent when you agree with our privacy policy in respective Service or enter into agreement with our sub-franchisee. Please draw your attention that you may opt-out your consent in certain cases (i.e. when and to the extent our sub-franchisees are able to service you without your consent) albeit we don't recommend doing that because in this case we may not guarantee that you receive services satisfying all standards that we impose on our sub-franchisees.

We may use both manual and automated systems, such as machine learning and artificial intelligence, to process your and/or your child's personal data.

Your and/or your child's personal data will not be used for any automated decision-making, including profiling. We do not sell, trade or otherwise transfer user's personal data to any third parties for commercial purposes.


5. WILL WE SHARE YOUR INFORMATION WITH ANYONE

IN SHORT: Yes, but we only do this with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

There are several situations when we can share your and/or your child's personal data, namely:

Your consent. You give us the consent to share your and/or your child's personal data with our other sub-franchisees in your region including, inter alia, if for whatever reason you terminate purchasing services from this sub-franchisee, terminate your other relations with such a sub-franchisee, or if we terminate our franchise agreement with that sub-franchisee. In all other cases (except for those outlined further in this section) we will request your consent to share your and/or your child's personal data.

Compliance. We may disclose your and/or your child's personal data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your and/or your child's personal data where we believe it is necessary to enforce, remedy, or apply our terms of service and other agreements; for debt collection; to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the rights, property or safety of any person (including Algoritmika Group, sub-franchisee, you or your child) and illegal activities, or as evidence in litigation in which we are involved.

Third-Party Service Providers. We may share your and/or your child's personal data with third party vendors, service providers, advertising companies, contractors, agents or other business partners who perform services for us or on our behalf and require access to such information to do that work and only to the extent they need such info to do that work. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity, arrange for joint sales, promotions, and events, enable us to operate our business or to offer you certain products, services or promotions. Some of those third-party service providers may use information about your or your child's visits to our websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. Unless described in this policy, we do not share, sell, rent or trade any of your and/or your child's personal data with third parties for their promotional purposes.

Business Transfers. We may share or transfer your and/or your child's personal data If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company. In such a case we may need to share information with that company and its advisors.

Affiliates. We may share your information within Algoritmika Group and with our affiliates, in which case we will require them to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

6. HOW, WHERE AND FOR HOW LONG DO WE STORE PERSONAL DATA

IN SHORT: We keep your and your child's data to the extent we need to fulfill the purposes outlined in this policy unless the law requires otherwise. We aim to protect your and your child's data with the use of a system of organizational and technical security measures.

Algoritmika Group does not retain your and/or your child's personal data any longer than it is required for attaining the purposes for which it were collected. Your and/or your child's personal data will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations.

If you are a person exercising parental rights with respect to a child, your and/or your child's personal data will be deleted once our sub-franchisee deletes it from the Platform. If this happens, we will also delete your and your child's respective personal data that we obtained directly within thirty ('30') calendar days.

If you are a representative of our potential sub-franchisee, we will delete your personal data within thirty ('30') calendar days after our last contact.

Please draw your attention that the advantage of our Platform is that you can always see your child's progress with services you obtained from our sub-franchisee irrespective of time elapsed from the completion of respective service (including in case we terminated our business relationships with that sub-franchisee). We will therefore store your and/or your child's personal data to extent we must satisfy your potential request to see child's progress with our sub-franchisee' services.

We will also continue keeping your and/or your child's personal data to the extent necessary for either of the following purposes:

· to send you newsletter, marketing and promotional communications (this you can change at any time)

· for legal and regulatory compliance purposes

· for general Services' improvement purposes

We will permanently delete or de-identify the above information in accordance with our standard data retention practices once all the above purposes cease to be applicable.

We will also permanently delete or de-identify your and/or your child's personal data once you specifically ask us to delete it.

It may happen that we are unable to fully delete or de-identify your information due to technical or other operational reasons (for example where information has been archived and stored in back-up systems). Where this is the case, we will take reasonable measures to securely isolate information from any further processing and store it until such time as we are able to delete or de-identify it.

Algoritmika Group has taken appropriate technical and organizational measures by using the latest technologies to protect your and/or your child's personal data against loss or unlawful processing but there cannot be 100% guarantee that would safeguard your and/or your child's personal data a from unpermitted disclosure or leakage.

While we will do all reasonable effort to protect your and/or your child's personal data, internet itself is not a secure means of transmission. Your internet connection is at your own risk. This is your responsibility that you and your child access to Services with the use of a secure internet connection. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to e-mails between you, your sub-franchisee and Algoritmika Group, at all times.


7. WHAT RIGHTS DO YOU HAVE

IN SHORT: You have certain rights with respect to your and/or your child's personal data that we collect and process.

You have a variety of rights granted to you pursuant to GDPR. Below we outline the main of them in brief albeit there are others that we did not list. Should you need a more detailed guidance, please contact us, our representative or independent GDPR specialist on your rights.

Right of consent withdrawal. You have the right to withdraw from us your consent to process your and/or your child's personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. For more details on this right please read article 7 of the GDPR.

Right of access. You have the right to obtain from us confirmation as to whether your and/or your child's personal data are being processed, and, where that is the case, access to that personal data, the information concerning how we process it and some other information. For more details on this right please read article 15 of the GDPR.

Right to rectification. You have the right to obtain from us the rectification of inaccurate your and/or your child's personal data. You also have the right to have incomplete personal data completed. For more details on this right please read article 16 of the GDPR.

Right to erasure ('right to be forgotten'). You have the right to obtain from us the erasure of your and/or your child's personal data, and we will erase that personal data without undue delay. For more details on this right please read article 17 of the GDPR.

Right to restriction of processing. You have the right to ask us to restrict processing your and/or your child's personal data. For more details on this right please read article 18 of the GDPR.

Right to object. You have the right to object on grounds relating to your particular situation to processing of your and/or your child's personal data and we will no longer process that personal data unless we are able to demonstrate compelling legitimate grounds for such processing. For more details on this right please read article 21 of the GDPR.

Right to data portability. You have the right to receive from us your and/or your child's personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. For more details on this right please read article 20 of the GDPR.

Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority, in particular, in the member EU state of your habitual residence, place of work or of an alleged infringement of the GDPR, about our collection and processing of your and/or your child's personal data. For more details on this right please read recital 141-143, article 12, 13, 15, 77 and others of the GDPR.

You can always manage the privacy of your and/or your child's personal data by updating your privacy settings, by managing marketing and promotional communications from us or changing your browser settings to opt-out of cookies in your browser settings (if you however disallow some or all of the cookies, the Services may not work).

We respond to all requests we receive from individuals in the EEA that are using the Services directed to the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.

To file a request or act on one of your rights, please contact us at the contact details provided above in section How to Contact Us.

8. DO WE PROCESS YOUR PERSONAL DATA OUTSIDE EEA

IN SHORT: We store your and/or your child's personal data in Finland and process it in Russia and Cyprus. Our sub-franchisee, who is the joint controller of your and/or your child's personal data, stores and processes the data in the respective EU member state. We will ensure an adequate level of protection for your and your child's rights and freedoms.

We store your and/or your child's personal data on our servers located in Finland and Russia. If we need to replace our Finish server, we will find another location in EU to continue storing your personal data in EU.

Since Algoritmika Russia is the Russian company and Algoritmika Cyprus is the Cypriot company, we will process your and/or your child's personal data in Russia and Cyprus. We are committed to ensuring an adequate level of protection for your rights and freedoms.

Given that certain ambiguity still exists regarding our processing status with respect to your and/or your child's personal data, we believe that we together with respective sub-franchisee are the joint controllers of your and/or your child's personal data. Taking account of this we are entering into data transfer agreements (a) between Algoritmika Russia and Algoritmika Cyprus, and (b) with each of our sub-franchisee to ensure our compliance with standard contractual clauses for data transfers between EU controllers and non-EU controllers.

Even if we transfer your and/or your child's personal data to another receiver, then such receiver would locate in the EEA being therefore a legal entity to which GDPR would apply.


9. HOW ARE WE CONNECTED WITH THIRD-PARTY APPLICATIONS, WEBSITES AND SERVICES

IN SHORT: We are generally not connected. If you go from your webpage to their applications, websites and services, this policy does not apply, and you are covered by their policies. Similarly, their policies do not work with our Services and you should carefully read our policy.

We are not responsible for the practices employed by any applications, websites or services linked to or from our Service, including the information or content contained within them.

You need to remember that when you use a link to go from our Service to another application, website or service, our privacy policy does not apply to those third-party applications, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on our Services, are subject to that third party's own rules and policies.



10. HOW DO WE SAFEGUARD CHILDREN'S PRIVACY

IN SHORT: We do not intentionally collect data directly from children under 16 years of age without the permission of a person exercising parental rights with respect to a child.

If you are a representative of our potential sub-franchisee and you are under 16 years old, you should immediately stop using our Services.

If you are a person exercising parental rights with respect to a child, please draw your attention to the following.

Services of our sub-franchisees are primarily consumed by children and we therefore need some personal data from them even if they are under 16. We however request our sub-franchisees to target their services to persons exercising parental rights with respect to a child and therefore we aim at receiving information regarding children under 16 from their parent or guardian or from children but with parents or guardians' consent.

We request our sub-franchisees to never knowingly enter in contract directly with a child and to always seek for a person exercising parental rights with respect to him or hem with the purpose that this person read and understand this policy and, further, contract with our sub-franchisee, if he or she decides so.

If you are parent or guardian and you are aware that your child has provided us with her or her personal data without you having knowledge of that, please contact us. If we become aware that we or our sub-franchisee have collected personal data from a child under age 16 without verification of parental consent, we will take steps to permanently remove that information from our servers.



11. WILL WE CHANGE THIS PRIVACY POLICY

IN SHORT: Yes, we will. We will always keep an updated version of our privacy policy on our webpage algorithmicschool.com/privacypolicy so you can always read it.

We will continually review our privacy policy to ensure that it accurately reflects the GDPR, our processing activities and where we process the personal data for a new purpose which was not indicated in the initial policy, then we will provide a notice of policy amendment to cover this.

We reserve the right to make changes or updates at any time. We will notify you of any changes by posting the new privacy policy on algorithmicschool.com/privacypolicy. We recommend that you review this privacy policy periodically. If we make material changes to the way we process your personal data, we will provide you notice and if required by applicable data protection laws seek your consent to those material changes.

Amendments to this privacy policy are effective only when they are posted on the link that we mentioned above.


12. OUT OF GDPR' SCOPE

IN SHORT: We receive some personal data of our potential sub-franchisees' employees, agents or other representatives. We are of the opinion that the use of this information by Algoritmika Russia is out of GDPR' territorial scope. We will, however, delete your data from our systems if you want.

When our potential sub-franchisee approaches us through our contact forms on our websites their representatives provide us with their personal data, such as, their name, country and city, contact phone number and e-mail address.

We maintain this data solely for the purpose of establishing and performing commercial relationships with our potential sub-franchisee. We do not use this information to offer our services directly to those individuals in EU and, even we receive some information from cookies, we do not intentionally monitor their behaviour. We therefore are of the opinion that the use of this information by Algoritmika Russia is out of GDPR' territorial scope.

If however you are an employee, agent or other representative of either of our EU potential sub-franchisee and you don't want that we store or use any data regarding you, please inform us immediately and we will delete your data from our systems as soon and to the extent it is practically possible.

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