Personal Data Processing Policy
This Policy sets out how the personal data of individuals (“Users”) is processed and protected when using the website flylabschool.com (the “Website”). It is drawn up in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable regulations of the Russian Federation.
1Data operator
The operator that organises and carries out the processing of personal data is:
- Individual entrepreneur Aleksandr Mikhailovich Kozelkov (FLYLAB flight school);
- INN (taxpayer ID): 772032406868;
- OGRNIP (registration no.): 317774600327514;
- Address: 111402, Moscow, Ketcherskaya st., 2, bldg. 2, apt. 81;
- Email for personal-data enquiries: hello@flylabschool.com.
2Key terms
Personal data — any information relating to a directly or indirectly identified or identifiable individual. Processing — any operation performed on personal data (collection, recording, storage, updating, use, transfer, anonymisation, blocking, deletion, destruction). Data subject — the User to whom the personal data relate.
3Personal data collected
The operator processes personal data that the User provides voluntarily when completing forms on the Website:
3.1. Course application form
- surname, first name (and patronymic if provided);
- date of birth;
- phone number;
- Telegram username;
- height and weight (needed to select equipment and assess flight safety);
- information on flying and sport experience, learning goals, owned equipment, wellbeing and any other details the User chooses to provide.
3.2. Product enquiry form (shop)
- surname and first name;
- phone number;
- email address;
- the product of interest and a comment.
The operator does not process special categories of personal data or biometric personal data. Height, weight and wellbeing data are processed solely to ensure flight-training safety and to select equipment.
4Purposes of processing
- handling training applications and communicating with the User;
- selecting a training programme and equipment, and assessing fitness to fly for safety purposes;
- handling product enquiries and providing advice;
- performing service contracts;
- sending informational and service messages related to the request.
5Legal grounds
- the User’s consent to the processing of personal data, given by ticking the relevant checkbox in the form before submission (Art. 6, Art. 9 of Federal Law No. 152-FZ);
- conclusion and performance of a contract to which the User is a party;
- requirements of the legislation of the Russian Federation.
6How data is processed
Personal data is processed with and without the use of automation means. The recording, systematisation, accumulation, storage, updating and retrieval of the personal data of citizens of the Russian Federation is carried out using databases located within the Russian Federation (Art. 18(5) of Federal Law No. 152-FZ).
The operator does not disclose personal data to third parties, except where necessary to perform a contract with the User or as required by law. The operator does not carry out cross-border transfers of personal data.
7Retention
Personal data is kept no longer than the processing purposes require. Data processed on the basis of consent is stored until the purposes are achieved or until the User withdraws consent, after which it is destroyed or anonymised unless the law provides otherwise.
8Rights of the data subject
- obtain information about the processing of their personal data;
- request that inaccurate, outdated or unlawfully obtained data be updated, blocked or deleted;
- withdraw consent to the processing of personal data;
- lodge a complaint with the supervisory authority (Roskomnadzor) or in court.
9Withdrawing consent and enquiries
To withdraw consent or exercise other rights, the User sends a request to hello@flylabschool.com or to the operator’s postal address. The request must contain details that allow the User to be identified. The operator handles requests within the statutory time limits.
10Cookies and analytics
The Website uses cookies — small text files stored in the browser — to make the Website work and for web analytics.
To collect anonymised statistics on traffic and user behaviour in order to improve the Website, we use the Yandex Metrica web-analytics service (operated by Yandex LLC, Russia). Through cookies the service collects technical data: IP address, browser and device information, referral sources, pages visited and actions on them (including via the “Session Replay”/Webvisor technology). This data is processed under Yandex Metrica’s terms. You can disable cookies in your browser settings — this does not affect the core functions of the Website.
11Data protection
The operator applies legal, organisational and technical measures to protect personal data against unauthorised or accidental access, destruction, alteration, blocking, copying or distribution: access control, encryption of the transmission channel (HTTPS) and storage on secure infrastructure located within the Russian Federation.
12Changes to this Policy
The operator may amend this Policy. The current version is always available on the Website at flylabschool.com/privacy/. Continued use of the Website after changes constitutes acceptance of the new version.
