Privacy Policy

1. General Provisions

1.1. This Personal Data Processing Policy sets out how Skills Up Limited, a company incorporated in Hong Kong (Business Registration No. 79371456-000-12-25-5), hereinafter the “Operator”, processes personal data and what measures it takes to keep them secure. The Operator processes personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “Ordinance”) and other applicable data-protection laws. Where the User is resident in another jurisdiction, any mandatory data-protection rights granted to the User by the laws of that jurisdiction also apply.

1.2. The Operator’s paramount objective is to respect human and civil rights and freedoms when processing personal data, including the right to privacy and to personal and family confidentiality.

1.3. This Policy applies to all information that the Operator may obtain about visitors to the website https://azatnurgaleev.com.

2. Definitions Used in this Policy

2.1. Automated processing of personal data — the processing of personal data by means of computing equipment.

2.2. Blocking of personal data — the temporary suspension of the processing of personal data, except where processing is necessary in order to correct the personal data.

2.3. Website — the body of graphical and informational materials, together with the computer programs and databases that make them available on the Internet at the address https://azatnurgaleev.com.

2.4. Personal data information system — the body of personal data contained in databases together with the information technologies and technical means that process them.

2.5. Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to attribute the personal data to a particular User or other data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without the use of automation, including collection, recording, systematization, accumulation, storage, correction (updating, modification), retrieval, use, transfer (provision of, access to), anonymization, blocking, deletion and destruction of personal data.

2.7. Operator — a legal entity or natural person which, alone or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of the processing, the categories of personal data and the operations performed on them.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://azatnurgaleev.com.

2.9. User — any visitor to the website https://azatnurgaleev.com.

2.10. Provision of personal data — actions aimed at disclosing personal data to a particular person or to a particular group of persons.

2.11. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons, including publication in the media, posting on information and telecommunications networks, or otherwise granting access to them.

2.12. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed and their content can no longer be recovered.

3. Principal Rights and Obligations of the Operator

3.1. The Operator has the right to: obtain from the data subject accurate information and/or documents containing personal data; continue processing personal data without the subject’s consent where there are lawful grounds for doing so under the applicable data-protection law; and determine on its own the composition and list of measures required to comply with its obligations under the Ordinance.

3.2. The Operator is obliged to: provide the data subject, at their request, with information concerning the processing of their personal data; organize the processing of personal data in the manner required by the Ordinance and other applicable data-protection law; respond to inquiries and requests from data subjects and their legal representatives within the periods set by that law; provide the competent data-protection authority — in Hong Kong, the Privacy Commissioner for Personal Data — with the information it requires, within the period stated in its request; publish or otherwise provide unrestricted access to this Policy; take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful acts; and cease processing and destroy personal data in the cases provided for by the Ordinance.

4. Principal Rights and Obligations of Data Subjects

4.1. Data subjects have the right to: receive information about the processing of their personal data, except where the applicable law provides otherwise; require the Operator to correct, block or destroy personal data that are incomplete, out of date, inaccurate, unlawfully obtained or not required for the stated purpose of processing; withdraw consent to the processing of personal data or require processing to cease; complain to the competent data-protection authority — in Hong Kong, the Privacy Commissioner for Personal Data — or to the courts about unlawful acts or omissions of the Operator in processing personal data; and exercise any other right granted to them by the Ordinance or by the mandatory data-protection law of their country of residence.

4.2. Data subjects are obliged to provide the Operator with accurate data about themselves and to inform the Operator of any correction (update, change) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without that subject’s consent, bear liability in accordance with the applicable law.

5. Principles of Personal Data Processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. Processing is limited to the achievement of specific, predefined and lawful purposes. Processing that is incompatible with the purposes of collection is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for incompatible purposes.

5.4. Only personal data that meet the purposes of processing are processed. The content and volume of the data processed correspond to the stated purposes; excessive data are not permitted.

5.5. The accuracy, sufficiency and, where necessary, currency of personal data are ensured. The Operator takes steps to delete or correct incomplete or inaccurate data.

5.6. Personal data are stored in a form that permits identification of the data subject for no longer than the purposes of processing require, unless a retention period is established by law or by the offer agreement. The data are destroyed or anonymized once the purposes of processing have been achieved or the need to achieve them has ceased.

6. Purposes of Processing

6.1. Conclusion and performance of the public offer agreement: taking out a subscription, making one-off purchases and booking sessions with the Provider, and granting access to the materials paid for. Data processed: first and last name, email address. Legal basis: the public offer agreement published on the Website.

6.2. Operation of the Account: creating an account, signing in to the Website, saving lesson progress, and uploading and publishing the User’s works. Data processed: first and last name, email address, images of works uploaded by the User. Legal basis: the consent of the data subject given upon registration on the Website.

6.3. Payment for services and refunds. Data processed: first and last name, email address, payment records (amounts, dates, statuses) and, in the case of a refund, the bank details stated by the User in the refund request. Legal basis: the public offer agreement, together with the accounting and tax record-keeping requirements that apply to the Operator and to the payment service processing the payment. The User’s bank card details are not transferred to and not stored by the Operator: the payment is processed by the payment service.

6.4. Informing the User about new materials, live streams and events by email. Data processed: first and last name, email address. Legal basis: the consent of the data subject.

6.5. Collection and processing of anonymized visitor data in order to improve the quality of the Website, including by means of authorized web-analytics services where such services are connected to the Website. Data processed: anonymized data, including cookies. Legal basis: the User’s browser settings permitting the use of cookies and JavaScript.

7. Conditions of Processing

7.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary for the performance of the public offer agreement to which the data subject is a party, and for the conclusion of such an agreement at the data subject’s initiative.

8. Collection, Storage, Transfer and Other Processing of Personal Data

8.1. The security of personal data is ensured by implementing the legal, organizational and technical measures required to comply with data-protection legislation. The Operator safeguards personal data and takes measures to prevent access by unauthorized persons.

8.2. The User’s password is stored as an irreversible hash: the Operator does not hold the password in plain text and cannot disclose it.

8.3. The User’s personal data are not transferred to third parties, except where required by law and where transfer is necessary to perform obligations under the offer agreement: to the payment service, in order to accept payments and issue refunds; and to hosting, file-storage and video-delivery providers, in order to operate the Website and the Account. Because the Operator and the services it relies on are based in different countries, personal data may be processed outside the User’s country of residence; the Operator takes reasonable measures to ensure an appropriate level of protection for such transfers. The Operator does not sell personal data and does not pass them on for third-party advertising.

8.4. If inaccuracies are found in the personal data, the User may correct them in the Account or by sending a notice to the Operator’s email address hello@azatnurgaleev.com marked “Correction of personal data”.

8.5. The period of processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the offer agreement or by law. The User may withdraw consent to the processing of personal data by sending a notice to hello@azatnurgaleev.com marked “Withdrawal of consent to the processing of personal data”.

8.6. The User may request deletion of their account and of the personal data associated with it by sending a request to hello@azatnurgaleev.com. Records of payments made are retained to the extent and for the period required by the accounting and tax laws applicable to the Operator.

8.7. Information collected by third-party services is processed in accordance with their terms of use and privacy policies. The Operator is not liable for the acts of such third parties.

8.8. Processing of personal data ceases once the purposes of processing have been achieved, on expiry of the consent, on withdrawal of consent, or where unlawful processing is identified.

9. Cookies

9.1. The Website uses cookies that are necessary for it to function: they store the fact that the User is signed in to the Account and the language the User has chosen.

9.2. The User may disable cookies in their browser settings. With cookies disabled, signing in to the Account and accessing the materials paid for may become impossible.

10. Works Published by the User

10.1. Works that the User uploads to the Account and publishes on the Website are shown to other users together with the name of their author.

10.2. The User may delete a published work in the Account at any time, or ask the Operator to do so at hello@azatnurgaleev.com.

11. Operations Performed on Personal Data; Confidentiality

11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, correction (updating, modification), retrieval, use, transfer (provision of, access to), anonymization, blocking, deletion and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of information over information and telecommunications networks.

11.3. The Operator and other persons who have obtained access to personal data are obliged not to disclose them to third parties and not to disseminate them without the consent of the data subject, unless otherwise required by applicable law.

12. Final Provisions

12.1. The User may obtain clarification on matters relating to the processing of their personal data by contacting the Operator by email at hello@azatnurgaleev.com.

12.2. Amendments to this Policy are published in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is available on the Internet at https://azatnurgaleev.com/privacy.

Operator’s Contact Details

Skills Up Limited

Email: hello@azatnurgaleev.com

Full registration details are listed on the “Contacts”. Payment and refund terms are set out in the Public Offer Agreement.