Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy (the «Policy») has been prepared in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 «On Personal Data» and defines the procedure for processing personal data and the measures taken by the Operator of the Quaize service (the «Service») to ensure their security.

The Operator's most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family secrets.

This Policy applies to all information that the Operator may receive about visitors to the website, users of the Service, and other personal data subjects.

2. Operator

The personal data operator is:

• Name: Artem Artemov (individual entrepreneur)
• Tax ID (INN): 773186690557
• Email: artem@artemov.me
• Email for personal data requests: support@quaize.ru

3. Definitions

• Personal data — any information relating directly or indirectly to a specific or identifiable natural person (personal data subject).
• Processing of personal data — any action (operation) or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction.
• User — a website visitor, or a registered or unregistered participant in the Service.
• Cookies — a small piece of data sent by a web server and stored on the User's device.

4. Legal Grounds for Processing

The Operator processes personal data on the following legal grounds:

• consent of the personal data subject to the processing of their personal data;
• a contract to which the personal data subject is a party, beneficiary, or guarantor (the terms of service and public offer);
• fulfillment of duties imposed by the legislation of the Russian Federation;
• exercise of the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated.

5. Categories of Subjects and Personal Data Processed

The Operator processes personal data of the following categories of subjects:

• visitors to the Service's website;
• registered users (teachers, authors, session hosts);
• game session participants (including minors — with the consent of a legal representative or an educational organization).

Personal data processed:

• full name (or pseudonym/nickname);
• email address;
• external service account data (when signing in via OAuth, including Yandex);
• data added by the User to the profile (avatar, bio, links);
• user-generated content (quizzes, questions, images);
• Service usage data (participation in games, results, statistics);
• technical data: IP address, session and cookie identifiers, browser type and version, device type, operating system, time zone, language;
• data from analytics and monitoring systems: PostHog, OpenReplay, Yandex Metrika.

The Operator does not process special categories of personal data (racial or ethnic origin, political views, religious beliefs, health, intimate life) or biometric personal data.

6. Purposes of Processing

• registration and identification of the User, providing access to the Service;
• providing and improving Service functionality (creating and running quizzes, participating in game sessions);
• communication with the User: notifications, responses to requests, informational and service messages;
• analysis of User behavior and Service quality, troubleshooting errors;
• ensuring the security of the Service and preventing abuse;
• performance of obligations under the contract (terms of service and public offer);
• compliance with the legislation of the Russian Federation.

7. Procedure and Conditions of Processing

Personal data is processed:

• with the consent of the personal data subject;
• in a mixed manner (with and without the use of automation tools);
• without transfer via the internal network of a legal entity;
• with transfer over the Internet using secure protocols (HTTPS/TLS).

Personal data is stored on servers located within the territory of the Russian Federation, in accordance with Part 5 of Article 18 of Federal Law No. 152-FZ.

8. Transfer of Personal Data to Third Parties

The Operator does not sell or transfer personal data to third parties, except in the following cases:

• with the explicit consent of the personal data subject;
• when engaging third parties (processors) to provide services necessary for the operation of the Service (hosting, email, analytics, payments), provided that they comply with the requirements of 152-FZ;
• in cases provided for by the legislation of the Russian Federation (upon request of authorized state bodies).

Cross-border transfer of personal data by the Operator is not carried out to countries that do not provide adequate protection of the rights of personal data subjects, without observing the requirements established by Article 12 of Federal Law No. 152-FZ.

9. Rights of the Personal Data Subject

The personal data subject has the right to:

• receive information regarding the processing of their personal data;
• demand clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data;
• appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court;
• protect their rights and legitimate interests, including seeking damages and compensation for moral harm.

To exercise these rights, the subject may send a request to: support@quaize.ru.

10. Personal Data Security Measures

The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions, including:

• encryption of data in transit (TLS/HTTPS);
• access control to personal data and privilege separation;
• regular backups;
• use of modern protection and monitoring tools;
• restricting employee and contractor access to personal data;
• timely software updates.

For more details on technical measures, see the Security Policy.

11. Processing and Storage Terms

Personal data is processed for the period necessary to achieve the purposes of processing, but no longer than required in accordance with the legislation of the Russian Federation. Personal data shall be destroyed or depersonalized:

• upon achievement of the purposes of processing;
• if the subject withdraws consent to processing;
• when the User deletes their account;
• upon detection of unlawful processing.

12. Use of Cookies

The Service uses cookies and similar technologies. Detailed terms are described in the Cookie Policy.

13. Changes to the Policy

The Operator has the right to make changes to this Policy. When changes are made, the last update date is indicated in the header of the Policy. The new version of the Policy takes effect from the moment it is posted on the website.

14. Contacts

For all questions related to the processing of personal data, including the exercise of the rights of the personal data subject, please contact: support@quaize.ru.