Personal Data Processing Policy
1. DEFINITIONS
1.1. Company - LLC "MORSKAYA PRAKTIKA", OGRN 1157746141057, INN 7729447745, KPP 772901001, address of location: Moscow, st. Pokryshkina, 8, room 5, phone: +7 (499) 110-28-82, e-mail: info@sea-practice.ru. The official address of the Company's website on the Internet: www.en-sea-practice.com.

1.2. Personal data processing Policy of Users of the Sites - the Policy for the processing of personal data, which applies to any user of any Site belonging to the Company, developed and approved by the Company in pursuance of the requirements of the Federal Law "On Personal Data" No. 152-FZ dated 27.07.2006, hereinafter referred to as according to the text of the document and in the user agreements on the Sites, as "Personal data processing policy" and / or "Policy".

1.3. Site - content filled by the Owner of the domain name and / or the Copyright Owner of the Site, and / or the User of the Site, located on the Internet.

1.4. Site User – a person and / or representative of a legal entity who has expressed interest in the Company and / or any other information and / or content posted on the Site by visiting the Site (going to the Site) at one of the specified addresses on the Internet, which at the moment of switching to the page of the Site provides (transfers) personal data (or part of it) to the Company and is a Subject in the meaning of the concept used in this Policy.

1.5. Subject - a person and / or legal entity that provided the Company with their personal data, including the Site Users, as well as other persons communicating with the Company by telephone connection and communication and / or by means of electronic correspondence, and / or by signing an agreement / offer invoices (including, but not limited to).

1.6. Personal data - any information relating directly or indirectly to a specific or identifiable individual (Personal Data Subject), including, but not limited to: last name, first name, patronymic, age, phone number, email address, passport data, IP address, postal address, photo and video materials, location information, date and time of visiting the Site, online identifier and other information that the Subject provides by filling out the forms / fields of the Site, or received by the Company through cookies at the time of the User's transition to the Site page.

1.7. Operator - government agency, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.8. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.9. Automated processing of personal data - processing of personal data using computer technology.

1.10. Provision of personal data - actions aimed at disclosing and / or transferring the personal data of the Subject of personal data to the Partner companies of the Company and / or Operators for the purpose of proper processing, storage and protection of personal data provided by the Subjects of personal data, as well as for the purpose of interaction of the Subject of personal data with Partners of the Society in the framework of the implementation of Educational programs.

1.11. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

1.12. Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

1.13. Depersonalization of personal data - actions, as a result of which it becomes impossible to determine the direct or indirect ownership of personal data to a specific Subject of personal data without using additional information.

1.14. Publicly available personal data - personal data of the Subject and / or a group of Subjects united by a single purpose (Team), which became publicly available (i.e. posted on the Site with the possibility of processing by an indefinite circle of persons) as a result of independent actions of the Subject and / or actions of other persons, but at their request.

1.15. Partners of the Company - legal entities (Russian and / or international) which have entered into a cooperation agreement with the Company in order to implement Educational programs, with the ability to process personal data of Subjects who have given consent to the Company to process them by any of the methods provided for in this Policy.

1.16. Cross-border transfer of personal data - the transfer of the personal data of the Subject to the territory of a foreign state to the authority of a foreign state and / or to a foreign legal entity in the manner of contractual interaction.

1.17. Educational programs - a set of educational activities carried out by the Society for the purpose of practical training on large sailing ships, or teaching yachting, or conducting educational and sports regattas, sailing expeditions and transitions.
2. GENERAL PROVISIONS
2.1. This Policy for the processing of personal data has been developed in accordance with the requirements of the Federal Law "On Personal Data" No. 152-ФЗ dated July 27, 2006 (hereinafter referred to as the "Law on Personal Data"), the Federal Law "On Information, Information Technologies and the Protection of Information "No. 149-FZ of July 27, 2006 (hereinafter – the "Law on Information"), and defines the procedure and principles for the processing of personal data of Personal Data Subjects, conditions, validity period of consent to the processing of personal data, collection, recording, systematization, accumulation, clarification, use, extraction, destruction, blocking, anonymization, deletion and transmission of this data.

2.2. The purpose of the adoption of this Policy is ensuring the compliance of the processing and protection of personal data in the Company with the legislation of the Russian Federation.

2.3. In the case of cross-border transfer of personal data (in the course of interaction with the Partners of the Company), the Company ensures the processing and protection of personal data in accordance with Regulation N 2016/679 of the European Parliament and the Council of the European Union "On the protection of individuals in the processing of personal data and on the free circulation of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) "(hereinafter -" EU Regulation "), taking into account the priority of applying the internal current legislation of the Russian Federation, and may be prohibited or limited in order to protect the foundations of the constitutional system of the Russian Federation, morality, health, rights and legitimate interests of citizens, to ensure the country's defense and state security.

2.4. The Company processes the following personal data of Users:

• Full Name (last name, first name, patronymic);
• E-mail address;
• phone number;
• mailing address;
• other personal data posted on the site and / or received by the Company in the process of interaction of the Subject with the Site.

2.5. The Company also processes other data that is automatically transmitted during the use of the Site through the software installed on the computer of an individual (subject of personal data):

• information about the browser used (or other program with which the site is accessed);
• IP address;
• cookie data.

2.6. The Company processes personal data of Personal Data Subjects by maintaining databases in automated, mechanical, manual ways in order to:

• identification of the Subject in order to provide the Subject with information support about Educational programs;
• providing the Subject with access to personalized resources of the Site (s) on the Internet;
• establishing feedback with the Subject, including, but not limited to: sending mailings, notifications in the form of SMS messages, emails, oral and written requests, processing requests and applications from the Subject;
• confirmation of the accuracy and completeness of the personal data provided by the Subject;
• informing the Subject about upcoming and ongoing events by the Company, including by telephone and SMS informing;
• providing the Subject with access to the Sites or services of the Partners of the Company in order to obtain information, updates and services of both the Company and the Partners of the Company. Partners receive the data of the Subjects when the latter visits or uses their services, or through third parties with whom they cooperate;
• for statistical and other research purposes, subject to the depersonalization of the personal data of the Subjects.

2.7. The processing of the Subject's publicly available personal data is carried out without his consent, however, in compliance with the principles of personal data processing.

This Policy applies to any actions of the Company in relation to the Personal Data of Users, participants, administrators, experts who interact directly with the Company in any of the forms specified in this Policy.
3. THE MOMENT OF THE SUBJECT'S CONSENT TO THE PROCESSING OF PERSONAL DATA
3.1. The Company notifies the Subject that, in accordance with this Policy, the following explicit, specific, conscious and free actions, confirming the Subject's awareness of the provisions of this Policy, are equated to the Subject's written consent to the processing of his personal data:

• the oral form, which is used when the Personal Data Subject is connected by telephone with the Company's employees, as a result of which the Subject is identified, the metadata of the conversation is recorded (in particular, from which number, at what time and how long the call was). In this case, any information provided by the Subject to an employee of the Company, directly or indirectly related to the Subject, is considered to be provided freely, voluntarily and with his unconditional consent;
• an electronic document signed by a simple electronic signature in the form of SMS. In accordance with the Federal Law of April 6, 2011 N 63-FZ "On Electronic Signature", a simple electronic signature is an electronic signature that is created by using codes, passwords or other means and confirms the fact of the formation of an electronic signature by a certain person. This kind of consent can be expressed in the form of entering an SMS code sent to the phone of the Subject of personal data when registering on the relevant Site;
• at the moment the Subject clicks the button on the Site next to the statement "I agree to the terms of the user agreement and the personal data processing policy." The Company receives from the specified Subject consent to the processing of personal data and with all the methods of information and interaction specified in this Policy;
• an electronic form in the form of consent expressed in an e-mail from the e-mail of the Personal Data Subject to the e-mail address of an employee of the Company or directly of the Company;
• at the time of signing the Offer Agreement in the event that the Company provides services to the Subject, although the latter does not act as a party to such an agreement, however, it is named (named) in its terms.
4. THE VALIDITY PERIOD OF THE SUBJECT'S CONSENT TO THE PROCESSING OF PERSONAL DATA AND THE PROCEDURE FOR REVOCATION
4.1. Consent is granted for an indefinite period. The subject is notified and agrees that this consent can be revoked by sending a written notification to the address of the Company specified in clause 1. of this Policy, by registered mail, sending with a list of attachments. The legal consequence of the withdrawal of consent is the loss of the Operator's right to process the personal data of this Subject, except in cases where the Operator has other grounds for processing such data provided for by the Personal Data Law (clauses 2 - 11, part 1 of article 6, part 1). 2 Art.10 and Part 2 Art.11 of the Law on Personal Data). Withdrawal of consent to processing is valid only for a future period of time and has no retroactive effect. Thus, the processing of personal data carried out by the Operator before such revocation will continue to be considered lawful after it.

4.2. In case of receiving mailings by e-mail, the Subject has the right to unsubscribe from the Company's mailings at any time by activating the "Unsubscribe" field contained in each e-mail, after which the e-mail address will be removed from the Company's mailing base and / or from the service mailing base, which the Society uses.
5. PRINCIPLES OF PROCESSING PERSONAL DATA
5.1. This Policy is posted on the Internet at https://en-sea-practice.com/privacy_policy for the purpose of providing unrestricted access to any interested person for review and pursues the following principles:

• processing of personal data is carried out on a legal and fair basis;
• the processing of personal data must comply with the goals stated in the collection of personal data;
• only personal data that meet the purposes of their processing is subject to processing;
• the content and volume of processed personal data should be minimally sufficient to achieve predetermined purposes of processing personal data;
• personal data processing processes must ensure the accuracy, sufficiency and relevance of personal data in relation to the purposes of their processing, as well as ensure timely deletion or clarification of incomplete or inaccurate data.

5.2. When processing personal data, the Company is guided by the minimum necessary composition of personal data to achieve the goals of obtaining personal data.
6. PERSONAL DATA PROCESSING CONDITIONS
6.1. The processing of personal data by the Company is carried out in accordance with the current legislation of the Russian Federation, international treaties and internal documents of the Company.

6.2. The processing of personal data is carried out with the explicit consent of the Subject of personal data or his legal representative to the processing of his personal data. The letters of consent of the Subjects are accumulated in the general database of the Company.

6.3. The processing of personal data can be carried out without the consent of the Subject of personal data (or upon withdrawal by the Subject of consent to the processing of personal data) if there are grounds specified in paragraphs 2-11 of part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of the Law on Personal Data.

6.4. The processing of special categories of personal data concerning race, political views, information that characterizes the physiological characteristics of a person and on the basis of which it is possible to establish his identity (biometric personal data), religious or philosophical beliefs, intimate life is not carried out by the Company.

6.5. Access to personal data of Personal Data Subjects (regardless of the type of media) is provided to the employees of the Company in accordance with their job responsibilities.

6.6. The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6.7. The Company has the right to entrust the processing of personal data to a third party with the consent of the Subject of personal data, unless otherwise provided by the current legislation of the Russian Federation, on the basis of an agreement concluded with this party (including a state or municipal contract), or by adopting an appropriate act by a state or municipal body.

6.8. A third party processing personal data on behalf of the Company is obliged to comply with the principles and rules for processing personal data provided for by the Law on Personal Data, ensuring the confidentiality and security of personal data during their processing. And if there is a cross-border transfer of data, the Company monitors compliance with the requirements of the EU Regulation, the Law on Personal Data and other current legislation, taking into account the priority of applying the domestic legislation of the Russian Federation.
7. RIGHTS OF SUBJECTS OF PERSONAL DATA
7.1. The subject of personal data has the right, in writing, by sending a letter, to demand that the Company clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate or not necessary for the stated purpose of processing, has the right to withdraw consent to the processing of personal data in accordance with this Policy and the current legislation of the Russian Federation, both in general and in part (for example, to withdraw consent to the use of his personal data in order to send mailings by the Company), has the right to receive information from the Company in in an understandable form on the transfer of Personal Data, as well as to take measures provided for by law to protect their rights.

7.2. In the cases and in the procedure established by the Law on Personal Data, the Personal Data Subject has the right to receive information from the Company regarding the processing of his personal data, including containing:

• confirmation of the fact of processing of personal data by the Company;
• legal grounds and purposes of personal data processing;
• the purposes and methods of processing personal data used by the Company;
• information about persons (with the exception of employees of the Company) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of a federal law;
• the processed personal data relating to the relevant Personal Data Subject, the source of their receipt, unless another procedure for submitting such data is provided for by federal law;
• other information provided for by the Personal Data Law or other federal laws.
8. INFORMATION ON THE MEASURES TAKEN TO PROTECT PERSONAL DATA
8.1. When processing personal data, the Company takes legal and organizational measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the legislation of the Russian Federation. The processing of Personal Data is carried out in accordance with the legislation of the Russian Federation and other regulatory legal acts, including the relevant state bodies that regulate the processing of personal data.

8.2. The Company develops and approves documents defining the Company's policy regarding the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the Russian Federation, eliminating the consequences of such violations;

8.3. The Company develops and implements local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of established procedures for processing personal data and eliminating the consequences of such violations;

8.4. Employees of the Company who are directly involved in the processing of personal data must be familiar with the provisions of the legislation of the Russian Federation on the processing of personal data, including the requirements for the protection of personal data, documents defining the policy of the Company in relation to the processing of personal data, local acts on the processing of personal data.