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Privacy

We are committed to ensuring that your privacy is protected and respected. This Privacy Policy, together with our Terms & Conditions and Cookie Policy, explains to you the basis on which any personal data that we collect from you, or that you provide to us, will be processed, used, and stored by us. 

About us
This website is operated by The Anglo-American School of Moscow located at 1 BEREGOVAYA STREET | 125367 MOSCOW, RUSSIA.

Children under 16 years of age
Children under 16 years of age may only obtain a profile on our website and use password-restricted areas with express parental consent. Any information obtained about children under 16 years of age shall be obtained, retained, and used in accordance with the terms of this Privacy Policy, the Terms & Conditions, and the Cookie Policy

If you do not consent to your child using our website, you must ensure that your child ceases all use of our website immediately.

The Anglo-American School of Moscow

Privacy Policy

Version effective as of November 20, 2019

1. General provisions

This Privacy Policy (the “Policy”) is adopted and effective in The Anglo-American School of Moscow (the “School” or “we”).

1.1. Policy objective

This Policy establishes how we process and protect the personal data of our students, staff, guests and other individuals.

1.2. Key terms used in the Policy

Personal data” means any information related directly or indirectly to a specific or identifiable individual.

Personal data may include, specifically, information that allows identifying an individual (e.g., first name, last name, passport data, and photographs) and additional information (e.g., postal address, email address, phone number, place of employment, job title, and marital status).

Personal data processing” means any automated or manual operation performed on personal data, including collecting, recording, systematising, gathering, storing, verifying the accuracy of (updating, altering), extracting, using, transferring (distributing, providing access to), depersonalising, blocking, deleting or destroying personal data.

Controller” means a government body, a municipal body, a legal entity or an individual that, independently or in cooperation with other entities, organises or conducts the processing of personal data. The Operator also determines the purpose for processing personal data, the content of personal data to be processed and the operations to be performed on personal data.

Automated personal data processing” means processing personal data with computing facilities.

Cross-border transfer of personal data” means transfer of personal data to the territory of a foreign country, to a foreign authority, a foreign individual or a foreign legal entity.

1.3.    Processing principles

  • When processing your personal data, we will adhere to the following principles:
  • Personal data must be processed in a lawful and fair manner.
  • The processing of personal data is to be limited to certain predefined and lawful purposes.
  • The personal data contents and degree of processing corresponds to the stated purposes of personal data processing.
  • We will make all reasonable effort to ensure the personal data we process are accurate, sufficient and, where necessary, up to date.
  • We will take all necessary action to ensure personal data security during processing.
  • We will respect the rights and lawful interests of the personal data subjects and ensure protection of such personal data during processing.

1.4. Personal data subjects’ rights and Controller’s obligations

Protecting your personal data rights and freedoms is pivotal to the way we operate. To ensure your rights and freedoms are protected, upon your request, we, as your personal data Controller, may:

  • confirm whether we process your personal data and will allow you to look through it within 30 days from the receipt of your request;
  • inform you on the source and contents of your personal data that we process;
  • inform you on the legal basis, purposes, terms and means of processing your personal data;
  • notify you on the cross-border transfer of your personal data made or planned;
  • notify you on the name and location of the organisations, which have access to your personal data and to which your personal data may be disclosed upon your consent;
  • notify you on the exercise of your rights during our processing of your personal data;
  • introduce the necessary changes to your personal data if you confirm it is incomplete, inaccurate or outdated within 7 business days from the date of the receipt of such confirmation and notify you on the changes made;
  • stop processing your personal data within 30 days from the date of the receipt of withdrawal of your consent provided if there are no other legal grounds;
  • stop processing your personal data if unlawful processing on our side is confirmed and notify you on remedial action taken;
  • destroy your personal data if unlawful receipt or unintended use thereof is confirmed within 7 business days from the date of the receipt of such confirmation and notify you on remedial action taken;
  • answer any questions related to your personal data we process.

For more information on how to contact the School and discuss these and other issues, please see section “How to contact the School”.

2. Collection and use of personal data

2.1 INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

•    Information you give us: You may give us information about you by filling in forms or completing editable fields on our website. This includes information you submit on our website when you create a user profile, subscribe to our services and/or newsletters, participate in discussion boards or other forums, enter a competition, promotion or survey, and/or when you report a problem with our website. The information you give us may include your name, address, e-mail address, phone number, photograph, and/or such other information as you may give us from time to time. 
•    Information we may collect about you is automatically logged: Each time you visit our website we may collect (automatically or otherwise) information including:
•    the Internet protocol (IP) address used to connect your computer to the Internet. This information identifies only the computer that is being used to view the website, and does not identify the user as an individual; and  
•    your web browser type and version, time zone setting, operating system, and the Uniform Resource Locators (URL) of the websites which you use immediately before and after our website. This information enables us to produce and review vital statistics about our website, in turn enabling us to develop our website to provide the best possible experience for our users.  
In order to ensure that we can provide you with a secure website which complies with user expectations and all necessary laws, we may also collect information which you submit through the use of any private messaging functionality on our website. Any such information which we collect will be used only for security and member rules, compliance purposes, and will not be used for other purposes such as advertising.
•    Information we receive from other sources: we may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and/or credit reference agencies) and may receive information about you from them from time to time.

COOKIES

Our website uses cookies for such purposes as distinguishing you from other users of our website, providing you with a seamless experience, and continually improving our website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

2.2 HOW WE USE THIS INFORMATION

We may use information held about you in the following ways:

Information you give to us - We may use this information
•    to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us;
•    to notify you about changes to our service; and/or
•    to ensure that content from our website is presented in the most effective manner for you and for your computer. 

Information we collect about you - With exception to any information collected through your use of any private messaging functionality on our website 
•    to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistics, and/or survey purposes;
•    to improve our website to ensure that content is presented in the most effective manner for you and for your computer; 
•    to allow you to participate in interactive features of our service, if and when you choose to do so;
•    as part of our efforts to keep our website safe and secure; and/or
•    to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

Any information collected through your use of any private messaging functionality on our website may be used to provide you with a secure website which complies with user expectations, and all necessary laws, member rules, and will not be used for any other purposes such as advertising.

•    Information we receive from other sources: we may combine this information with information you give to us, and which we collect about you. We may use this information, including the combined information, for the purposes set out above (depending on the types of information we receive).
•    Marketing: we will only use your information to provide you with details of products, services, and/or content about which you have specifically requested information, and/or which we identify as being relevant to you from previous products and/or services purchased through, or content viewed on, our website. We will communicate this information to you only via electronic means (email and/or SMS), provided that you have not opted out of either or both of these forms of communication. Should you later wish to opt out of receiving these communications, then you may do so by following the “unsubscribe” link at the bottom of any such communication, or otherwise emailing or writing to us using our contact information provided later in this Privacy Policy. 

2.3 DISTRIBUTION OF YOUR INFORMATION

We may disclose your information:

•    to any member of our group, being our subsidiaries and/or holding company (and its subsidiaries); 
•    in the event that our business (or any party of it) is bought by, or integrated with, a third party business, to our advisers and/or the prospective purchase and their advisers, and potentially also onto the new owners of the business (or relevant part of the business);
•    if we are obliged by law or binding regulation to disclose certain information about you, or in order to enforce or apply our Terms of Use, as a result of illegal or potentially illegal activities (including fraud) and/or for the protection of our or others’ intellectual property rights; 
•    in aggregated form to third parties for the purpose of their or our analysis, including for the purpose of fraud protection and assisting us with the improvement or optimisation of our website; and/or
•    to third parties for the purpose of providing our website and any products and/or services which are offered on or by the website now or in the future, provided that any such third parties shall be required to treat your information at least in accordance with this Privacy Policy.  

3.  Legal grounds for personal data processing

The School processes personal data on legal grounds only, such as an obligation to process personal data by law, the need to process to execute a contract signed with the data subject or in its interest, personal data subject’s consent or consent of its legal representative, and other grounds stipulated by applicable legislation.

4.  Procedure and conditions for personal data processing

4.1.  Who will have access to your personal data

We may process your personal data both using automated tools including information and telecommunication networks and manually.

We do not make decisions that may affect your rights and interests based on automated processing of your personal data only.

4.2.  Who will have access to your personal data

A limited number of the School’s staff and third parties with whom we have signed appropriate agreements will have access to your personal data. When collecting your personal data, we will inform you on the third parties that will have access to your data and on the purposes we transfer your data to such third parties.

We will ensure our staff comply with this Policy. Delegating your personal data processing to third parties, we oblige them to ensure protection and security of your personal data.

The School may be obliged to disclose your data upon request from law-enforcement agencies and other bodies under applicable law.

We will make all reasonable effort to prevent disclosure of your data to third parties who have no legal grounds to process such data and to ensure protection of your personal data during transfer outside the School including cross-border transfers.

4.3.    Your personal data protection

We will take all necessary legal, organisational and technical measures to ensure your personal data security under applicable law. In particular, the School:

  • appoints a person responsible for organising personal data processing and protection;
  • establishes internal personal data protection rules including limitation of the access rights of our staff and authorised third parties to a necessary minimum;
  • implements legal, organisational and technical protection measures in compliance with legal requirements, current data security threats and impact on you in case of potential security breach;
  • trains its staff responsible for personal data processing to follow secure data processing rules and personal data processing requirements of the School and applicable laws;
  • registers all operations with personal data and oversees compliance with and effectiveness of the established protection procedure;
  • detects and investigates personal data security breaches and takes action to prevent and mitigate the impact of such incidents including, where necessary, recovering data where it is altered or destroyed.

4.4.    The term of personal data processing

The School will be processing your personal data no longer than is necessary to fulfil the purpose they were collected. The personal data may be retained longer where law establishes other retention periods.

5.  Updating, correction, deletion or destruction of personal data, responses to data subjects’ requests for access to personal data.

The School retains accurate personal data and updates them. You may request to delete, correct or amend your personal data if they are inaccurate or if you believe the School has no right to process them under applicable law. You may also request access to your personal data.

For more detail on how to file a request, see section “How to contact the School”.

The School will permanently destroy your personal data where it is established that the School does not have any legal grounds to process them, e.g., where the retention period has expired or where you have withdrawn your consent. The School will also ensure permanent destruction of your personal data by third parties processing your personal data under the School’s instructions.

6.  How to contact the School

If you have any questions on how we apply, use, change or delete the personal data you provided to us or if you want to stop any further communication with the School, please contact us by sending a free-format message to the following email address: communications@aas.ru.

Alternatively, you can send your message to communications@aas, to the attention of the Data Protection, Privacy and Compliance office responsible for organisation of personal data processing.

In all your correspondence with the School, please specify your first and last name, ID (if applicable), personal data processing circumstances that cause doubt or concern, and a detailed account of the matter. We will make all reasonable efforts to handle your request promptly.

In some cases, to handle a request, we will need to identify the data subject who filed it. This may entail a personal visit of the data subject to the School and provision of an ID document and (or) preparation of a written request signed personally by the personal data subject or its legal representative.

7. How to learn about the changes in this Policy

If the school makes changes to this Policy, the updated version will reflect all changes and we will notify you on them by updating the effective date of the Policy indicated on the title page. Without prejudice to your rights, under current legislation, we reserve the right to amend this Policy from time to time to reflect new technology, legal developments, new regulations, and business practices.

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